The UK’s new qualifying asset holding company regime

The draft legislation in the Finance Bill for the QAHC regime provides a vehicle that should allow the UK to compete with Luxembourg as a holding company location. The rules have moved on significantly, and generally improved, since L-day. Helpful changes include the dropping of potential eligibility criteria relating to minimum capital and independent management, an (overall) broadening of the definition of ‘qualifying fund’ and some improved tax benefits (e.g. a widening of the withholding tax exemption and increased availability of the remittance basis for fund managers). We also have much additional detail on how the regime will operate, such as how companies will join, what information must be provided to HMRC for each accounting period and how breaches will be addressed.