Regulation 2 Amendments to the Authorised Investment Funds (Tax) Regulations 2006

(1)

The Authorised Investment Funds (Tax) Regulations 2006^f1 are amended as follows.

(2)

In regulation 18 (interest distributions: general), after paragraph (2) insert—

“(2A)
For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, an interest distribution is treated as not being a tax-interest expense amount^f2 of the authorised investment fund.”

(3)

In regulation 69Z16 (PAIF distributions (interest))^f3, after paragraph (2) insert—

“(2A)
For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, a PAIF distribution (interest) is treated as not being a tax-interest expense amount of the company.”

(4)

In regulation 69Z61 (TEF distributions (non-dividend))^f4, after paragraph (2) insert—

“(2A)
For the purposes of Part 10 (Corporate Interest Restriction) of TIOPA 2010, a TEF distribution (non-dividend) is treated as not being a tax-interest expense amount of the Tax Elected Fund.”

Annotations

Footnotes

f1: S.I. 2006/964; relevant amending instruments are S.I. 2008/705 and 2009/2036.
f2: A new Part 10 was inserted into the Taxation (International and Other Provisions) Act 2010 (c. 8) by paragraph 1 of Schedule 5 to the Finance (No. 2) Act 2017; “tax-interest expense amount” is defined in section 382 of that Part.
f3: Regulation 69Z16 was inserted by S.I. 2008/705.
f4: Regulation 69Z61 was inserted by S.I. 2009/2036.