The Qualifying Private Placement Regulations 2015
The Regulations specify conditions in relation to securities further to section 888A of the Income Tax Act 2007 (c. 3) (“ITA 2007”). Section 888A of ITA 2007 was inserted by section 23 of the Finance Act 2015 (c. 11). Securities described in the Regulations (“relevant securities”) which meet the specified conditions and the conditions in section 888A(2)(a) and (b) are qualifying private placements. The duty to deduct a sum representing income tax under section 874 of ITA 2007 does not apply to such placements.