Legislation – Finance Act 2022
SCHEDULE 2Qualifying asset holding companies
PART 7Treatment of certain amounts payable by a QAHC
Late interest
50
(1)
Section 373(1) of CTA 2009 (late interest treated as not accruing until paid in some cases) does not apply to a qualifying debit.
(2)
For the purpose of this paragraph, a debit is “qualifying” if—
(a)
it relates to interest payable under a debtor relationship of a QAHC,
(b)
the QAHC is party to the relationship for the purposes of its QAHC ring fence business, and
(c)
the interest to which the debit relates accrues at a time when the QAHC is a QAHC.
(3)
Where a QAHC is party to a debtor relationship partly for the purposes of its QAHC ring fence business and partly for another purpose, sub-paragraph (1) applies only to the proportion of the qualifying debit that is attributable to the QAHC ring fence business (apportioned on a just and reasonable basis).
(4)
In this paragraph “debit” and “debtor relationship” are to be construed in accordance with Part 5 of CTA 2009.