Corporation Tax Act 2010 section 357LF

Section 357LE: interpretation

Section 357LF defines three key terms — "qualifying period", "relevant disregarded income" and "beneficial entitlement" — used in the investment manager 20% rule under section 357LE.

• A qualifying period is either the single accounting period in which the transaction takes place, or a period of up to five years made up of two or more complete accounting periods that includes that one.
• Relevant disregarded income is the company's total income for the accounting periods within the qualifying period that comes from transactions carried out by the investment manager on the company's behalf, where the investment manager would not (ignoring the 20% rule) be treated as a Northern Ireland regional establishment (NIRE) of the company.
• A person has a beneficial entitlement to relevant disregarded income if they hold, or may acquire, a beneficial entitlement attributable to that income through holding an interest in property representing the income or an interest or rights in the company itself.
• The relevant interests and rights include any interest in property in which the relevant disregarded income is wholly or partly represented (whether or not it gives an immediate right to a share of profits), and any interest in or rights relating to the company.