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Finance Bill 2022: further amendments

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The Public Bill Committee passed the following government amendments to Finance Bill 2022 on 14 December:

Schedule 2: Qualifying asset holding companies

  • amendments 1 and 2, expanding the definition of ‘investment management profit-sharing arrangements’ to include entitlements to performance-based rewards (‘carried interest’) that are not held by the person providing the investment management services to which they relate
  • amendments 3 and 6, providing that a fund that is 70% controlled by category A investors meets the diversity of ownership condition
  • amendment 4, allowing existing funds marketed before the commencement of the QAHC regime to be treated as meeting Condition A of the genuine diversity of ownership condition in the Offshore Funds (Tax) Regulations, SI 2009/3001 reg 75(2) if certain information has been produced by the fund and has been made available to HMRC, and
  • amendment 5, adjusting the rules for determining whether a fund is close.

The following government amendments will be considered by the committee when it continues its work in January:

Schedule 15: Large businesses: notification of uncertain tax treatment

  • amendments 7 and 9, ensuring that, where provision for uncertain PAYE or VAT liabilities is recognised in the accounts of a company or partnership, the accounts may be finalised before HMRC is required to be notified of the uncertainty under Sch 15;
  • amendments 8 and 10, aiming to ensure that Sch 15 operates as intended where provision for uncertain liabilities is recognised in the accounts of a partnership.

The Public Bill Committee was scheduled to reconvene on Wednesday, 5 January 2022.

Issue: 1558
Categories: News