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Home / Simons-Taxes /Corporate tax /Part D7 Financial service sectors /Division D7.1 Qualifying asset holding companies (QAHCs) /Becoming a qualifying asset holding company / D7.106 Qualifying asset holding companies—ownership condition
Commentary

D7.106 Qualifying asset holding companies—ownership condition

Corporate tax

The ownership condition is set out in FA 2022, Sch 2, Pt 1, para 3. It limits the proportion of 'relevant interests' that non-'Category A investors' can have in the company or in any 'enhanced class' of the company's profits or assets to 30%. A QAHC must take reasonable steps to monitor that the ownership condition continues to be met1. See IFM40250 for HMRC guidance on this.

What constitutes a 'relevant interest' is set out at 'Relevant interests' below.

Category A investors are 'good' investors, and include a range of institutional investors (such as most pension funds (both UK and overseas), charities and authorised long-term insurance businesses). 'Qualifying funds' are also Category A investors. This definition is discussed in more detail at 'Relevant interests' below.

An enhanced class of profits or assets is a particular class of profits or assets where a company has issued securities which entitle their holders to a greater proportion of such profits or assets than to other profits or assets of the company. Securities for this purpose means ordinary

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Web page updated on 17 Mar 2025 13:32