IFM40110 - Overview: Introduction

Finance Act 2022 introduced a regime for the taxation of qualifying asset holding companies (QAHCs) and certain payments that QAHCs may make. The policy background is explained at IFM40120 and the structure of the legislation is summarised at IFM40140.

A company that meets certain conditions (IFM40200+ ) may become a QAHC. No more than 30 percent of a QAHC may be owned by investors which are not diversely held funds or certain institutional investors.

A QAHC is expected to hold and manage investments. It may do this in-house, or it may contract out this activity, for example, to the manager of a fund which owns the QAHC. The QAHC cannot carry on a trade except where it is ancillary to the investment business of the company and not carried on to a substantial extent.

A QAHC is subject to corporation tax in the same way as other companies, but some tax rules are modified – see IFM40130.