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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Authorised investment funds (AIFs): qualified investor schemes: the genuine diversity of ownership condition and HMRC enquiry powers

Enquiry powers

Normal HMRC enquiry powers will apply to returns submitted by a qualified investor scheme (QIS).

For example, HMRC may undertake an enquiry and find that a QIS has made tax returns on the basis that it believed it had fulfilled the genuine diversity of ownership condition but in fact it had not met the required criteria. If so, then HMRC will amend the QIS’s self assessment tax return, after issuing a closure notice, on the basis that it should have been taxed as a close investment holding company. However, any assessments will be subject to a right of appeal in the normal way.