# Finance Act 2022, Paragraph 43: Application of corporate interest restriction rules (consolidation of QAHC stacks)

Extent: E+W+S+N.I.

(1) Sub-paragraph (2) applies where—
(a) a QAHC (“P”) would not, apart from that sub-paragraph, be a member of a multi-company worldwide group,
(b) P has a wholly-owned subsidiary (“W”) which it does not hold as a market value investment,
(c) W is a QAHC, and
(d) P is either—
(i) not a wholly-owned subsidiary of another QAHC, or
(ii) is such a subsidiary but is held as a market value investment.
(2) For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph—
(a) P is the ultimate parent of a worldwide group, and
(b) W, and any consolidated subsidiary of W—
(i) is a member of that group and not of any other worldwide group, and
(ii) is a consolidated subsidiary of P.
(3) Sub-paragraph (4) applies where—
(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),
(b) M has a wholly-owned subsidiary (“N”) which it does not hold as a market value investment,
(c) N is a QAHC, and
(d) apart from that sub-paragraph, N would not be a member of G.
(4) For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph, N, and any consolidated subsidiary of N—
(a) is a member of G and not of any other worldwide group, and
(b) is a consolidated subsidiary of M and any other member of G in relation to which M is a consolidated subsidiary.

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Source: https://www.legislation.gov.uk/ukpga/2022/3/schedule/2/paragraph/43 (the official version)
Page: https://openlegislation.uk/finance-act-2022/schedule-2/paragraph-43
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.