Qualifying asset holding companies

The qualifying asset holding company (QAHC) regime is an elective tax-privileged regime available to certain holding companies (referred to as ‘asset holding companies’ or ‘AHCs’) that are used in collective and institutional investment structures to hold investment assets. The main focus of the regime is on alternative fund structures, which are typically closed-ended, non-retail funds which hold assets across a range of private market investment strategies—chiefly credit, private equity and real estate investments.

The QAHC regime was introduced on 1 April 2022 to encourage funds to base their AHCs in the UK where that would otherwise make sense (eg where the investment manager is based in the UK). Traditionally, despite a high concentration of deal professionals and asset management expertise in the UK, Luxembourg has been the preferred location for holding companies, due to its broad treaty network and framework of tax reliefs. Ireland has also offered an attractive framework. Exploring ways to address some of the tax-related barriers to establishing AHCs in the UK formed part of the wider review of the UK funds regime, launched at Spring Budget 2020, to consider tax

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