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D7.115 Tax consequences of the QAHC regime

There a some immediate tax consequences of becoming a qualifying asset holding company (QAHC) as well as numerous ongoing tax benefits of being within the regime. These are discussed in more detail below.

The provisions relating to groups of companies are modified by the QAHC regime. The implications of this are discussed at D7.120.

There are also some modifications to certain tax provisions to ensure they work correctly for QAHCs. These include the transfer pricing rules and corporate interest restriction and there are specific provisions for certain loan relationships. QAHCs are also treated as close companies for the purpose of the charge to tax on loans to participators (see D3.401C). These modifications to the tax rules are discussed in more detail at D7.125.

There are also tax consequences when a company ceases to be a QAHC. These are discussed at D7.135.

In addition, there is an exemption from stamp duty and stamp duty reserve tax on a transfer to a QAHC of its own shares or loan capital¹.