Paragraph 29

After section 259ND insert—

“Qualifying institutional investors etc

Meaning of “qualifying institutional investor” etc

259NDA

(1)

This section has effect for the purposes of this Part.

(2)

References to “qualifying institutional investor” have the meaning given by paragraph 30A of Schedule 7AC to TCGA 1992.

(3)

A qualifying institutional investor is “based” in a territory—

(a)

if it is resident for tax purposes in the territory, or

(b)

where it is not resident anywhere for tax purposes, if it is established in the territory.”