IFM40920 - Gains exemption: overseas land

FA22/SCH2/PARA53(1)

Gains realised on disposals of overseas land by qualifying asset holding companies (QAHCs) are exempt from corporation tax.

This is the case even if rent derived from that land is not taxable in a foreign jurisdiction, and so does not benefit from the exemption at FA22/SCH2/PARA52 (IFM40800) and therefore falls outside the QAHC’s ring fence business (IFM40350).

‘Land’ is defined at FA22/SCH2/PARA58 as including:

1. Buildings and structures;
2. Any estate, interest or right in or over land;
3. Land under the sea or otherwise covered by water.