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Asset holding company regime: the ownership condition

Damien Crossley and Rhiannon Kinghall Were (Macfarlanes) examine the most complex of the conditions contained in the new regime.

Following several years of stakeholder engagement and consultation the new UK asset holding company regime is ready to launch. From 1 April 2022 qualifying asset holding companies (QAHCs) will be able to elect into a new bespoke tax regime offering investment funds the opportunity to base their under the fund investment holding structures in the UK rather than in locations such as Luxembourg or Ireland.

The reasons for the introduction and the benefits on offer under the regime are well rehearsed (see ‘The UK asset holding company regime: a quacking idea!’ (James McCredie) Tax Journal 2 September 2021). Instead this article concentrates on the ownership condition which will in effect determine whether a QAHC can be used. The legislation is contained in Sch 2...

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