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.