Unless an exemption or relief applies, payments of yearly interest that have a UK source are subject to UK withholding tax at the basic rate (20%) or, from 6 April 2027, at the savings basic rate (22%). For more details, see Practice Note: UK withholding tax on yearly interest. This Practice Note outlines the exemption from UK withholding tax that: • is contained in section 888A of the Income Tax Act 2007 (ITA 2007) and the Qualifying Private Placement Regulations 2015, SI 2015/2002 (QPP Regs) • took effect on 1 January 2016, and • applies to interest paid: ◦ by a corporate borrower in respect of an unlisted security or loan that qualifies as a qualifying private placement (QPP) and should be able to apply to bond issues and bilateral and syndicated loans—see: What is a qualifying private placement? and Creditor certificates below ◦ to a lender that is resident in a qualifying territory, ie in the UK or in certain tax treaty jurisdictions—see: Conditions relating to the

A QROPS is a foreign pension scheme that HMRC recognises as being capable of accepting a transfer value from a UK-registered pension scheme.

An overseas pension scheme that meets certain requirements set by HMRC. A qualifying recognised overseas pension scheme (QROPS) can receive the transfer of UK pension benefits requested on or after 9 March 2017 without incurring the overseas transfer charge in certain circumstances. The QROPS program was launched on 6 April 2006 as a part of new legislation with the objective of simplifying pensions.

Service of a member used when determining whether the member is entitled to short service benefit.

Employment analysis: Section 97(2) of the Employment Rights Act 1996 (ERA 1996) provides that, when determining a claimant’s qualifying service for an unfair dismissal claim, the effective date of termination (EDT) is to be extended by the notice required to be given by section 86. Section 97(2) incorporates the entirety of section 86. This means that any potential extension to the EDT under section 86(1) (to include the statutory minimum notice period) is subject to section 86(6) which preserves the right for a party to give no notice where it is entitled to treat the contract of employment as terminable by reason of the conduct of the other party. As a result, there will be no deemed extension to the EDT by the statutory minimum notice period where the employer is entitled summarily dismiss the employee, eg in a case of gross misconduct, according to the EAT.

a company (“the subsidiary”) is a qualifying subsidiary of another company (“the relevant company”) if the following conditions are met. The conditions are that— (a) the subsidiary is a 51% subsidiary of the relevant company, (b) no person other than the relevant company, or another of its subsidiaries, has control of the subsidiary, and (c) no arrangements are in existence by virtue of which either of the conditions in paragraphs (a) and (b) would cease to be met.

An exemption from the requirement to audit individual accounts for a financial year available to companies that meet the statutory requirements. CA 2006, ss 479A–479C allow certain qualifying subsidiaries to take advantage of an exemption from audit. Subject to exemptions, and certain conditions for eligibility, a company is exempt from the requirements relating to the audit of individual accounts for a financial year if it is a subsidiary undertaking, and its parent undertaking is established under the law of the UK and all its members agree to the exemption in respect of the financial year in question.

For the purposes of this Part, a trade is a qualifying trade if— (a) it is conducted on a commercial basis and with a view to the realisation of profits, and (b) it does not at any time in period B consist wholly or as to a substantial part in the carrying on of excluded activities.

Since its introduction in September 2021, the Solicitors Qualifying Examination (SQE) has been gradually replacing the training contract route to qualification and become the means of qualification following an apprenticeship. To qualify as a solicitor under the SQE, the candidate must: • have a UK degree in any subject (or a qualification or experience that is equivalent to a degree—this would include a solicitor apprenticeship) • pass two SQE assessments, and • have two years’ full-time (or full-time equivalent) qualifying work experience (QWE) The candidate must also satisfy the SRA’s character and suitability requirements. This Practice Note explains the SRA’s requirements for QWE and practical considerations for employers offering training and work experience to aspiring solicitors. For information on the SQE more generally, see Practice Note: The Solicitors Qualifying Examination (SQE). For information on the training contract route to qualification, see subtopic: Training contracts. For information on the apprenticeship route to qualification, see Practice Note: Solicitor apprenticeships. Qualifying work experience requirements Candidates must complete at least two years’ full time (or full-time equivalent) QWE.

A tax year in which someone has qualifying earnings, or credits of earnings, of at least 52 times the Lower Earnings Limit.

Assessing the value of an investment by examining mainly non-numeric characteristics such as management, people, process etc.

The process by which a developer ensures that standards are met during manufacturing.