Paragraph 1 Introduction

United Kingdom

(1)

This Part of this Schedule (after this paragraph) sets out the conditions that must be met for a company to be a qualifying asset holding company (a “QAHC”).

(2)

Parts 2 and 3 of this Schedule—

(a)

set out how a company becomes, and ceases to be, a QAHC, and

(b)

set out some of the consequences of becoming or ceasing to be a QAHC (for example, the effect on a company’s accounting periods).

(3)

Part 4 makes provision about groups of companies that include QAHCs.

(4)

Part 5 makes provision about the application of provisions about close companies, exchange gains and basis of accounting to QAHCs.

(5)

Part 6 makes provision about the application of transfer pricing rules and corporate interest restriction rules to QAHCs.

(6)

Part 7 makes provision about the treatment of certain amounts payable by a QAHC.

(7)

Part 8 makes provision in relation to an overseas property business of a QAHC.

(8)

Part 9 makes provision about the taxation of disposals by QAHCs of overseas land and certain shares.

(9)

Part 10 provides for an exemption from stamp duty and stamp duty reserve tax on the repurchase by an QAHC of its own shares or loan capital.

(10)

Part 11 amends ITA 2007 to provide for an exemption from the duty to deduct under section 874 of that Act (withholding tax).

(11)

Part 12 makes supplementary provision (including provision about the meaning of terms used in this Schedule).