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SCHEDULES

SCHEDULE 2U.K.Qualifying asset holding companies

PART 3U.K.Ceasing to be a QAHC

Corporation tax consequences of ceasing to be a QAHCU.K.

31(1)For the purposes of corporation tax, when a QAHC ceases to be a QAHC—

(a)a new accounting period begins on at the beginning of the day after the day on which it ceased to be a QAHC, and

(b)accordingly, its previous accounting period ended at the end of the day on which it ceased to be a QAHC.

(2)The following are to be treated, for the purposes of corporation tax, as sold by a QAHC immediately before it ceased to be a QAHC and reacquired by that company immediately after the start of that new accounting period—

(a)any overseas land it holds;

(b)any loan relationship or derivative contract the QAHC is party to for the purposes of an overseas property business of the QAHC, to the extent (apportioned on a just and reasonable basis)—

(i)the relationship or contract is attributable to those purposes, and

(ii)profits arising from that relationship or contract were exempt from corporation tax as a result of paragraph 52(4);

(c)any qualifying shares it holds.

(3)The sale and reacquisition deemed under sub-paragraph (2) is to be treated as being for a consideration equal to the market value of the assets immediately before the QAHC ceased to be a QAHC.

(4)Paragraph 11 of Schedule 7AC to TCGA 1992 has effect as if any reference to a “deemed disposal and reacquisition” did not include a deemed sale and reacquisition under sub-paragraph (2) of this paragraph.