Section 615 — Corporation Tax Act 2010: Umbrella companies

Umbrella companies 615 1 In this section “ umbrella company ” means an open-ended investment company—

a whose instrument of incorporation provides arrangements for separate pooling of the contributions of the shareholders and the profits or income out of which payments are made to them, and b whose shareholders are entitled to exchange rights in one pool for rights in another.

2 References in this section to a part of an umbrella company are to a separate pool.

3 For the purposes of this Chapter—

a each of the parts of an umbrella company is to be regarded as an open-ended investment company, and b the umbrella company as a whole is not to be regarded as an open-ended investment company.

4 The umbrella company as a whole is not to be regarded as a company for any other purpose of the Tax Acts unless an enactment expressly provides otherwise.