Commentary

D8.103 Umbrella companies and schemes

Corporate tax
Corporate tax | Commentary

D8.103 Umbrella companies and schemes

Corporate tax | Commentary

D8.103 Umbrella companies and schemes

Umbrella company

An umbrella company has the meaning given by CTA 2010, s 615 (formerly ICTA 1988, s 468A(4)) and a reference to a part of an umbrella company is construed accordingly1. For these purposes, each part of an umbrella company is regarded as an open-ended investment company. However, the umbrella company as a whole is not regarded as an open-ended investment company2.

In relation to a part of an umbrella company, any reference to investments or to scheme property of an open-ended investment company apply as if a reference to such of the investments or

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