267S Treatment of certificate owner

Summary

This section sets out the tax treatment of an owner of an “investment certificate”.

Details

(1) The certificate owner shall not be treated as having a legal or beneficial interest in the assets held by the qualifying company.

(2) The income, profit, gains or losses arising from the underlying asset in an “investment transaction” will be regarded as income, profits, gains or losses of the certificate issuing company and that company will be chargeable to Corporation Tax accordingly.

(3) The certificate owner will not be entitled to capital allowances on the underlying assets in the transaction.

Relevant Date: Finance Act 2019