Paragraph 6 Interpretation of ScheduleF1

In this Schedule—

• “qualifying foreign asset” means an asset that—

  1. (a)

     is situated outside the United Kingdom, and

  2. (b)

     does not derive at least 75% of its value from UK land (see Schedule 1A);

• “qualifying foreign gain” means—

  1. (a)

     a chargeable gain accruing on the disposal of a qualifying foreign asset,

  2. (b)

     a chargeable gain treated as accruing as a result of section 3 (gains of non-UK resident close companies attributed to UK residents) where the gain accruing to the non-UK resident close company to which the deemed gain relates accrued on the disposal of a qualifying foreign asset, or

  3. (c)

     a qualifying QAHC gain,

  but a chargeable gain falling within paragraph (a) or (b) is not a qualifying foreign gain if it is a gain to which paragraph 1(2) of Schedule 1 applies (pre-2025-26 gains subject to the remittance basis);

• “qualifying foreign loss” means a loss accruing on the disposal of an asset that is a qualifying foreign asset;

• “qualifying QAHC gain” means the foreign proportion (see paragraph 46(4) to (6) of Schedule 2 to FA 2022) of a chargeable gain accruing F2to an individual who provided investment management services in connection with investment arrangements to which a QAHC is party on the disposal of shares in F3the QAHC that were acquired during the course of the provision of those services;

• F4“QAHC” and “investment management services” have the meanings they have in that Schedule.