SCHEDULES

SCHEDULE 2Qualifying asset holding companies

PART 6Transfer pricing and corporate interest restriction rules

43Application of corporate interest restriction rules (consolidation of QAHC stacks)

1

Sub-paragraph (2) applies where—

a

a QAHC (“P”) would not, apart from that sub-paragraph, be a member of a multi-company worldwide group,

b

P has a wholly-owned subsidiary (“W”) which it does not hold as a market value investment,

c

W is a QAHC, and

d

P is either—

i

not a wholly-owned subsidiary of another QAHC, or

ii

is such a subsidiary but is held as a market value investment.

2

For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph—

a

P is the ultimate parent of a worldwide group, and

b

W, and any consolidated subsidiary of W—

i

is a member of that group and not of any other worldwide group, and

ii

is a consolidated subsidiary of P.

3

Sub-paragraph (4) applies where—

a

a QAHC (“M”) is a member of a multi-company worldwide group (“G”) (including as a result of the application of sub-paragraph (2) or the previous application of this sub-paragraph),

b

M has a wholly-owned subsidiary (“N”) which it does not hold as a market value investment,

c

N is a QAHC, and

d

apart from that sub-paragraph, N would not be a member of G.

4

For the purposes of Part 10 of TIOPA 2010, paragraph 42 and this paragraph, N, and any consolidated subsidiary of N—

a

is a member of G and not of any other worldwide group, and

b

is a consolidated subsidiary of M and any other member of G in relation to which M is a consolidated subsidiary.