Part 6 Transfer Pricing and Corporate Interest Restriction Rules
Finance Act 2022 (2022 c 3) | Legislation

Part 6 Transfer Pricing and Corporate Interest Restriction Rules

Transfer pricing: participation condition always met for investors in a QAHC etc

40

(1)     For the purposes of section 147(1) of TIOPA 2010 (basic pre-condition), where the affected persons are—

(a)     a QAHC, and

(b)     a person with a sufficient connection to the QAHC,

the participation condition in section 148 of that Act is treated as met.

(2)     An affected person (“A”) has a sufficient connection to the QAHC if—

(a)     A has a relevant interest in the QAHC or in an enhanced class of the QAHC, or

(b)     any of the persons with such an interest has a relationship with A such that the participation condition in that section would have been met had the affected persons been A and that person (instead of A and the QAHC).

(3)     In this paragraph, and in paragraph 41, “affected person” is to be construed in accordance with Part 4 of that Act.

Transfer pricing: no small

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