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SCHEDULES

SCHEDULE 8Corporate interest restriction

PART 1Amendments of Part 10 of TIOPA 2010

Identifying members of a worldwide group

12After section 454 insert—

Investment managers
454AInvestments held by investment managers

(1)This section applies where—

(a)an entity (“S”) is a member of a worldwide group as a result of one or more other members of the group managing S and holding rights or interests in relation to S,

(b)the entity managing S does so in the ordinary course of carrying on a business of providing investment management services, and

(c)the management of S is not coordinated to any extent with the management by any person of any other entity.

(2)For the purposes of this Part—

(a)the group does not include entities that are subsidiaries of S, and

(b)accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group.

(3)In this section “subsidiary” has the meaning given by international accounting standards.