Finance Bill 2016 - Changes to section 110 of the Taxes Consolidation Act 1997

Qualifying companies within the meaning of section 110 of the Taxes Consolidation Act 1997 (“Section 110 companies”) enjoy tax neutrality, meaning that negligible tax is payable by a Section 110 company to the extent that the income and gains it earns are payable to investors, either as interest on the funding it has obtained or as payments under certain agreements (eg Total Return Swaps).

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