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

Investments held by investment managers

Section 454A excludes certain entities from a worldwide group where they are managed by an independent investment manager in the ordinary course of business and the management is not coordinated with the management of other entities.

• Where an entity ("S") would only be part of a worldwide group because an investment manager holds rights or interests in it and manages it, S can be excluded from the group provided the management is carried out in the ordinary course of an investment management business and is not coordinated with the management of any other entity.
• In the general case, S and any of its subsidiaries are treated as not being part of the worldwide group, meaning none of them counts as a consolidated subsidiary of any group member.
• Where S is a partnership or another transparent entity, S itself may remain in the group, but its subsidiaries are excluded and are not regarded as consolidated subsidiaries of any group member.
• The term "subsidiary" takes its meaning from international accounting standards.

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