Taxation (International and Other Provisions) Act 2010 section 259NDA

Meaning of "qualifying institutional investor" etc.

Section 259NDA defines what a "qualifying institutional investor" means and how to determine where such an investor is "based" for the purposes of the hybrid mismatch rules in Part 6A of TIOPA 2010.

  • The definition of "qualifying institutional investor" is imported from paragraph 30A of Schedule 7AC to the Taxation of Chargeable Gains Act 1992.
  • A qualifying institutional investor is considered "based" in a territory if it is tax-resident there.
  • If the investor is not tax-resident anywhere, it is treated as based in the territory where it is established.
  • These definitions apply throughout Part 6A of TIOPA 2010, which deals with hybrid and other mismatches.

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