Certain tax provisions are modified by the qualifying asset holding company (QAHC) regime to ensure they work correctly for QAHCs. HMRC guidance can be found at IFM40600.
Close companies and QAHCs
The close company provisions apply more stringently to QAHCs1. All QAHCs are subject to the charge to tax on loans to participators (see D3.401C). This is because non-close QAHCs are treated as close companies for the purposes of the loans to participators and other rules in CTA 2010, ss 455–464D (Pt 10, Ch 3–3B).
Loan relationships and QAHCs
SI 2005/3422, reg 5 is amended by the QAHC rules to ensure that the loan relationship exchange gains and losses rules (see D1.731) apply as intended2. The amendments allow and exchange gain or loss of an asset or liability to be calculated by reference to other relevant currencies. A QAHC may borrow in one currency but make investments in another currency (or currencies). See also HMRC guidance at IFM40630, which includes
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Web page updated on 17 Mar 2025 13:34