{
  "url": "https://openlegislation.uk/authorised-investment-funds-tax-regulations-2006/regulation-69X",
  "json_url": "https://openlegislation.uk/authorised-investment-funds-tax-regulations-2006/regulation-69X.json",
  "legislation": "uksi/2006/964",
  "legislation_title": "The Authorised Investment Funds (Tax) Regulations 2006",
  "legislation_url": "https://openlegislation.uk/authorised-investment-funds-tax-regulations-2006",
  "path": "regulation/69X",
  "kind": "regulation",
  "number": "69X",
  "heading": "Ring-fencing of tax-exempt business",
  "text": "(1) For the purposes of corporation tax, the business of F (tax-exempt) shall be treated as a separate business (distinct from—\n(a) any business carried on by F (pre-entry),\n(b) any business carried on by F (residual), and\n(c) any business carried on by F (post-cessation)).\n(2) For the purposes of corporation tax, F (tax-exempt) shall be treated as a separate company (distinct from—\n(a) F (pre-entry),\n(b) F (residual), and\n(c) F (post-cessation)).\n(3) In particular—\n(a) a loss incurred by F (tax-exempt) may not be set off against the net income of F (residual),\n(b) a loss incurred in respect of F (residual) may not be set off against the net income of F (tax exempt),\n(c) a loss incurred in respect of F (pre-entry) may not be set off against the net income of F (tax-exempt) (but this regulation does not prevent a loss of that kind from being set off against profits of F (residual)),\n(d) a loss incurred by F (tax-exempt) may not be set off against profits arising to F (post-cessation) (in respect of business of any kind), and\n(e) receipts accruing after entry but relating to business of F (pre-entry) shall not be treated as receipts of F (tax-exempt).\n(4) In paragraph (3) a reference to a loss includes a reference to a deficit, expense, charge or allowance.\n(5) Section 392B of ICTA (ring-fencing of losses from overseas property business) shall not apply to business of F (tax-exempt).\n(6) Paragraphs 5B and 5C of Schedule 28AA to ICTA (transfer pricing: exemption for small and medium enterprises) shall not apply to an open-ended investment company to which this Part applies (whether to F (tax-exempt) or to F (residual)).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 4A inserted (6.4.2008) by The Authorised Investment Funds (Tax) (Amendment) Regulations 2008 (S.I. 2008/705), regs. 1, 5"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2006/964/regulation/69X",
    "retrieved_at": "2026-10-29T04:30:57.523890+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}