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FA 2022, Sch 2, Part 4 contains a number of specific provisions relating to groups of companies containing a qualifying asset holding company (QAHC). HMRC guidance on QAHCs and groups can be found at IFM40500.

Where a group company disposes of¹:

1. Ìý

   •ÌýÌýÌýÌý any overseas land

2. Ìý

   •ÌýÌýÌýÌý any loan relationship or derivative contract that the QAHC will be party to for the purposes of its overseas property business to the extent (apportioned on a just and reasonable basis) the relationship or contract is attributable to those purposes and profits arising from it will be exempt from corporation tax under the QAHC rules

3. Ìý

   •ÌýÌýÌýÌý any qualifying shares (broadly shares other than those which derive 75% or more of their value from UK land, see C2.1151 and 'Corporation tax consequences of becoming a QAHC' at D7.115)

4. Ìý

   •ÌýÌýÌýÌý any other asset that will be within the QAHC ring fence business of the QAHC

(and