IFM40110 - Overview: Introduction

Finance Act 2022 introduced a regime for the taxation of qualifying asset holding companies (QAHCs) and certain payments that QAHCs may make. »Ê¹ÚÌåÓýapp policy background is explained at IFM40120 and the structure of the legislation is summarised at IFM40140.

A company that meets certain conditions (IFM40200+ ) may become a QAHC. No more than 30 percent of a QAHC may be owned by investors which are not diversely held funds or certain institutional investors.

A QAHC is expected to hold and manage investments. It may do this in-house, or it may contract out this activity, for example, to the manager of a fund which owns the QAHC. »Ê¹ÚÌåÓýapp QAHC cannot carry on a trade except where it is ancillary to the investment business of the company and not carried on to a substantial extent.

A QAHC is subject to corporation tax in the same way as other companies, but some tax rules are modified � see IFM40130.