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