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Prompt tweaks to the qualifying asset holding companies regime

James Burton and Naomi Lawton (Allen & Overy) review some welcome changes to a helpful regime. 

The UK’s qualifying asset holding company (QAHCs) regime has been in force for little more than a year (it was introduced by the Finance Act 2022 with effect from 1 April 2022). However in its recent Finance (No. 2) Bill 2022/23 published on 23 March 2023 the UK government has already proposed a number of amendments tweaks and clarifications.

The QAHCs regime constitutes one of the government’s first substantive efforts to attract further investment to the UK in a post-Brexit environment. The regime is designed to facilitate investment by reducing tax friction; broadly the intention is that investors should be taxed no less favourably than had they invested in the underlying assets directly. The UK hopes that the regime will offer a useful alternative to the Irish and...

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