On 20 July 2022, the UK government published draft legislation
for the Finance Bill 2022-2023.
Of particular interest are amendments to be made to the
qualifying asset holding company (QAHC) regime that was introduced
from 1 April this year.
The regime is part of the UK government's attempt to
increase the attractiveness of the UK as a jurisdiction for asset
management and introduces a simplified tax regime applicable to
QAHCs that should, broadly, tax investors as if they had invested
directly in the underlying assets. Please see our submission to the
2021 PIF Annual Review and Outlook
here for the circumstances in which the regime is available and
its benefits.
The QAHC regime was introduced reasonably quickly and contained
some limitations on how an asset holding company owned by a private
fund could qualify as a QAHC. In particular, one of the main
conditions to qualify as a QAHC is that the asset holding company
is owned as to at least 70% by what are
