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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Debt cap: groups affected: collective investment schemes

Exemption for collective investment schemes

Under the provisions of TIOPA10/S339 a collective investment scheme cannot be the ultimate parent of the worldwide group. The aim of this provision is to ensure that where a fund or other collective investment vehicle owns two or more trading groups, each separate trading group is treated as a worldwide group in its own right for the purposes of the debt cap rules. A number of funds of this nature will be partnerships and so will be excluded from being an ultimate parent underTIOPA10/S340(1). However, this provision ensures that funds that take other legal forms can be similarly excluded.

A collective investment scheme for the purposes of the debt cap rules means a collective investment scheme within the meaning of section 235 of the of the Financial Services and Markets Act 2000.