Taxes Consolidation Act 1997 section 267S

Treatment of certificate owner

Section 267S sets out the tax treatment of the owner of an investment certificate issued as part of an Islamic finance arrangement.

• The certificate owner is not regarded as having any legal or beneficial interest in the assets held by the qualifying company.
• All income, profits, gains or losses from the company's assets (including changes in asset value) belong to the qualifying company and are chargeable to corporation tax accordingly.
• The certificate owner cannot claim capital allowances under Part 9, section 670, Part 29 or any other provision of the Tax Acts in respect of the company's assets.
• This ensures clarity over which party is taxable on asset income and entitled to allowances, removing doubts that might arise from the certificate's link to the underlying assets.