Corporation Tax Act 2010 section 615

Umbrella companies

Section 615 defines what an "umbrella company" is for corporation tax purposes and explains how each of its separate sub-funds is treated as an independent open-ended investment company (OEIC) rather than the umbrella entity being treated as a single company.

• An umbrella company is an open-ended investment company whose constitution provides for separate pooling of shareholder contributions and the profits or income from which payments are made, and whose shareholders can exchange rights in one pool for rights in another.
• Each separate pool (sub-fund) within the umbrella company is treated as a standalone open-ended investment company in its own right for the purposes of this chapter.
• The umbrella company as a whole is not treated as an open-ended investment company, and is not regarded as a company for any other purpose of the Tax Acts unless legislation expressly provides otherwise.
• This treatment mirrors the equivalent provision for umbrella schemes under section 619 of the same Act.