{
  "url": "https://openlegislation.uk/finance-act-2022/schedule-2/paragraph-43",
  "json_url": "https://openlegislation.uk/finance-act-2022/schedule-2/paragraph-43.json",
  "legislation": "ukpga/2022/3",
  "legislation_title": "Finance Act 2022",
  "legislation_url": "https://openlegislation.uk/finance-act-2022",
  "path": "schedule/2/paragraph/43",
  "kind": "paragraph",
  "number": "43",
  "heading": "Application of corporate interest restriction rules (consolidation of QAHC stacks)",
  "text": "(1) Sub-paragraph (2) applies where—\n(a) a QAHC (“P”) would not, apart from that sub-paragraph, be a member of a multi-company worldwide group,\n(b) P has a wholly-owned subsidiary (“W”) which it does not hold as a market value investment,\n(c) W is a QAHC, and\n(d) P is either—\n(i) not a wholly-owned subsidiary of another QAHC, or\n(ii) is such a subsidiary but is held as a market value investment.\n(2) For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph—\n(a) P is the ultimate parent of a worldwide group, and\n(b) W, and any consolidated subsidiary of W—\n(i) is a member of that group and not of any other worldwide group, and\n(ii) is a consolidated subsidiary of P.\n(3) Sub-paragraph (4) applies where—\n(a) a QAHC (“M”) is a member of a multi-company worldwide group (“G”) (including as a result of the application of sub-paragraph (2) or the previous application of this sub-paragraph),\n(b) M has a wholly-owned subsidiary (“N”) which it does not hold as a market value investment,\n(c) N is a QAHC, and\n(d) apart from that sub-paragraph, N would not be a member of G.\n(4) For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph, N, and any consolidated subsidiary of N—\n(a) is a member of G and not of any other worldwide group, and\n(b) is a consolidated subsidiary of M and any other member of G in relation to which M is a consolidated subsidiary.",
  "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/43",
    "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."
}