IFM41260 - Administrative requirements: entry notifications

FA22/SCH2/PARAS 14 and 16

Before a company can join the QAHC regime it must meet the eligibility criteria (IFM40200+) and submit an entry notification specifying the date on which it is intended that the company should become a QAHC (which cannot be earlier than the date of the notification). The notification must be made through the relevant GOV.UK page.

Where a company meets all the eligibility criteria on its chosen entry date, the process is straightforward. The company must make a standard entry notification on a date no later than its chosen entry date.

However, it is also possible for a company to join the QAHC regime on an entry date even if it does not meet all of the eligibility criteria on that entry date. In this scenario, a company must meet all the eligibility criteria on the chosen entry date except for the ownership condition, so long as the company reasonably expects to meet the ownership condition within the first two years after its chosen entry date (see IFM40320). The company must make an entry notification on a date no later than its chosen entry date. Note that this entry notification is different to the standard entry notification.

Non-UK resident companies

A company which is resident in an overseas jurisdiction can submit an entry notification with a specified future date of entry but being UK tax resident is an eligibility criterion and therefore on the specified date of entry, the company must be UK resident as well as meeting all the other eligibility criteria (except for the ownership condition in circumstances mentioned above).

Note that this entry notification requires more information than the standard entry notification. It must also state the territory in which the company is resident, its registration number in that territory and the date on which it intends to become UK resident. A company does not, however, need a Unique Taxpayer Reference (UTR) to make an entry notification and in the case of a non-UK incorporated company it might be that one has yet to be issued at the point the entry notification is made.

If a non-UK resident company submits an entry notification with a specified future entry date but the company is not UK tax resident on that entry date, the entry notification will be invalid and a new notification will be required before the company can enter the QAHC regime.

Agent acting on behalf of a client

The entry notification can be completed by an agent, but requires express confirmation that the person making the notification (the notifier) is an agent acting on behalf of a client. This can be problematic where the notifier does not prepare the tax returns of the QAHC and so is not already registered as an authorised agent.

Any such notifier can still complete the entry notification as agent for a client provided they also send an email to the QAHC team (see IFM41210) explaining the situation and copying in a representative from their client.

Where a stack of companies wishes to join the QAHC regime on the same day

If a stack of companies wishes to join the QAHC regime on the same day, then a separate entry notification should be made for each company with the same day of entry specified in the notification. If a company lower down the stack requires its parent be a QAHC in order to be able to be eligible itself then, as long as the parent company enters the regime on the same day (or earlier), the subsidiary will be treated as being eligible to join (as long as all other required criteria have been met).