Alongside its formal response to the consultation, the government is publishing draft legislation across both of these areas, which will be introduced in the next Finance Bill.

A qualifying asset holding company must be at least 70% owned by diversely owned funds — these must be managed by regulated managers or certain institutional investors, and exist to help move capital, income and gains between investors and underlying investments.

The aim is to recognise circumstances where intermediate holding companies are used to facilitate the flow of capital, income and gains between investors and underlying investments, so that investors are taxed broadly as if they invested in the underlying assets and the intermediate holding companies pay no more tax than is proportionate to the activities they perform. 

The regim