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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Investment managers

  • Section 454A Investments held by investment managers
  1. Investment managers
  2. Investments held by investment managers

Section 454A | Investments held by investment managers

From legislation.gov.uk

(1)This section applies where—

(a)an entity (“S”) would, apart from this section, be a member of a worldwide group as a result of one or more other members of the group managing S and holding rights or interests in relation to S,

(b)the entity managing S does so in the ordinary course of carrying on a business of providing investment management services, and

(c)the management of S is not coordinated to any extent with the management by any person of any other entity.

(1A)Except in a case within subsection (2), for the purposes of this Part—

(a)the group does not include S (or its subsidiaries), and

(b)accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group.

(2)Where S is a partnership or another transparent entity, for the purposes of this Part—

(a)the group does not include entities that are subsidiaries of S, and

(b)accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group.

(3)In this section “subsidiary” has the meaning given by international accounting standards.

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