267S Treatment of certificate owner.

(1) For the purposes of the Tax Acts, the owner of the investment certificate shall not be regarded as having a legal or beneficial interest in the assets held by the qualifying company.

(2) Income, profits, gains or losses arising from or attributable to the assets held by the qualifying company (including any increase or decrease in the value of the asset) shall be income, profits, gains or losses, as the case may be, of the qualifying company and the qualifying company shall be chargeable to corporation tax accordingly.

(3) The owner of the investment certificate shall not be entitled to an allowance under Part 9, section 670, Part 29 or any other provision of the Tax Acts relating to the making of allowances in accordance with Part 9 in respect of expenditure on the assets held by the qualifying company.