{
  "url": "https://openlegislation.uk/finance-act-2022/schedule-2/paragraph-31",
  "json_url": "https://openlegislation.uk/finance-act-2022/schedule-2/paragraph-31.json",
  "legislation": "ukpga/2022/3",
  "legislation_title": "Finance Act 2022",
  "legislation_url": "https://openlegislation.uk/finance-act-2022",
  "path": "schedule/2/paragraph/31",
  "kind": "paragraph",
  "number": "31",
  "heading": "Corporation tax consequences of ceasing to be a QAHC",
  "text": "(1) For the purposes of corporation tax, when a QAHC ceases to be a QAHC—\n(a) a new accounting period begins on at the beginning of the day after the day on which it ceased to be a QAHC, and\n(b) accordingly, its previous accounting period ended at the end of the day on which it ceased to be a QAHC.\n(2) The following are to be treated, for the purposes of corporation tax, as sold by a QAHC immediately before it ceased to be a QAHC and reacquired by that company immediately after the start of that new accounting period—\n(a) any overseas land it holds;\n(b) any loan relationship or derivative contract the QAHC is party to for the purposes of an overseas property business of the QAHC, to the extent (apportioned on a just and reasonable basis)—\n(i) the relationship or contract is attributable to those purposes, and\n(ii) profits arising from that relationship or contract were exempt from corporation tax as a result of paragraph 52(4);\n(c) any qualifying shares it holds.\n(3) The sale and reacquisition deemed under sub-paragraph (2) is to be treated as being for a consideration equal to the market value of the assets immediately before the QAHC ceased to be a QAHC.\n(4) Paragraph 11 of Schedule 7AC to TCGA 1992 has effect as if any reference to a “deemed disposal and reacquisition” did not include a deemed sale and reacquisition under sub-paragraph (2) of this paragraph.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2022/3/schedule/2/paragraph/31",
    "retrieved_at": "2026-10-29T08:57:50.927298+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."
}