Commentary

D8.126 Tax implications

Corporate tax
Corporate tax | Commentary

D8.126 Tax implications

Corporate tax | Commentary

D8.126 Tax implications

Qualified investor schemes (QIS) authorised by the Financial Conduct Authority (formerly the Financial Services Authority1) must meet the genuine diversity of ownership condition (D8.111) to qualify for authorised investment fund tax treatment2. From this date a QIS that meets this condition will be taxed as any other authorised investment fund and investors will similarly be taxed as if they had invested in an ordinary authorised investment fund. For HMRC commentary, see HMRC Investment Funds Manual (IFM02300 onwards).

If the genuine diversity of ownership condition is not met by the QIS:

  1.  

    (a)     the close investment holding company rules (repealed

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