IFM40140 - Overview: structure of the legislation
The rules for qualifying asset holding companies (QAHCs) are contained within FA22/SCH2.
The legislation is structured as follows:
Part | Provision | IFM guidance pages |
---|---|---|
1 | Conditions that must be met for a company to be a QAHC | IFM40200+ |
2 | How a company becomes a QAHC and the consequences | IFM40300+ |
3 | How a company ceases to be a QAHC and the consequences | IFM40400+ |
4 | Groups of companies that include QAHCs | IFM40500+ |
5 | Application of certain tax rules: close companies, exchange gains, basis of accounting | IFM40600+ |
6 | Application of other tax rules: transfer pricing, corporate interest restriction | IFM40650+ |
7a | Treatment of certain amounts payable by a QAHC: distribution rules | IFM40720 |
7b | Treatment of certain amounts payable by a QAHC: hybrid and other mismatch rules | IFM40730 |
7c | Treatment of certain amounts payable by a QAHC: remittance basis | IFM41000+ |
7d | Treatment of certain amounts payable by a QAHC: purchase of own shares | IFM40740 |
7e | Treatment of certain amounts payable by a QAHC: transactions in securities | IFM40750 |
7f | Treatment of certain amounts payable by a QAHC: late interest | IFM40760 |
7g | Treatment of certain amounts payable by a QAHC: deeply discounted securities | IFM40770 |
8 | Overseas property business of a QAHC | IFM40800+ |
9 | Chargeable gains exemption on the disposals of overseas land and certain shares | IFM40900+ |
10 | Exemption from stamp duty and stamp duty reserve tax on the repurchase by an QAHC of its own shares or loan capital | IFM41100+ |
11 | Withholding tax exemption | IFM40780 |
12 | Meaning of terms used |