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Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010 s 454A

s 454A Investments held by investment managers

(1) This section applies where— (a) an entity (“S”) would, apart from this section, be a member of a worldwide group as a result of one or more other members of the group managing S and holding rights or interests in relation to S, (b) the entity managing S does so in the ordinary course of carrying on a business of providing investment management services, and (c) the management of S is not coordinated to any extent with the management by any person of any other entity. (1A) Except in a case within subsection (2), for the purposes of this Part— (a) the group does not include S (or its subsidiaries), and (b) accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group. (2) Where S is a partnership or another transparent entity, for the purposes of this Part — (a) the group does not include entities that are subsidiaries of S, and (b) accordingly, none of those entities is regarded as a consolidated subsidiary of any member of the group. (3) In this section “ subsidiary ” has the meaning given by international accounting standards.

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