{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-454A",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-454A.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/454A",
  "kind": "section",
  "number": "454A",
  "heading": "Investments held by investment managers",
  "text": "(1) This section applies where—\n(a) an entity (“S”) would, apart from this section, be a member of a worldwide group as a result of one or more other members of the group managing S and holding rights or interests in relation to S,\n(b) the entity managing S does so in the ordinary course of carrying on a business of providing investment management services, and\n(c) the management of S is not coordinated to any extent with the management by any person of any other entity.\n(1A) Except in a case within subsection (2), for the purposes of this Part—\n(a) the group does not include S (or its subsidiaries), and\n(b) accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group.\n(2) Where S is a partnership or another transparent entity, for the purposes of this Part—\n(a) the group does not include entities that are subsidiaries of S, and\n(b) accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group.\n(3) In this section “subsidiary” has the meaning given by international accounting standards.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 454A and cross-heading inserted (retrospectively) by Finance Act 2018 (c. 3), Sch. 8 paras. 12, 23(1)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 454A(1)(a) substituted (with effect in accordance with Sch. 3 para. 30-36 of the amending Act) by Finance (No. 2) Act 2023 (c. 30), Sch. 3 para. 18(2)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "S. 454A(1A) inserted (with effect in accordance with Sch. 3 para. 30-36 of the amending Act) by Finance (No. 2) Act 2023 (c. 30), Sch. 3 para. 18(3)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Words in s. 454A(2) substituted (with effect in accordance with Sch. 3 para. 30-36 of the amending Act) by Finance (No. 2) Act 2023 (c. 30), Sch. 3 para. 18(4)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/454A",
    "retrieved_at": "2026-10-29T09:10:17.008829+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."
}