1st Apr 2021 09:37
(Alliance News) - Hipgnosis Songs Fund Ltd said its conversion into an investment trust company takes effect on Thursday, and it will be treated as resident in the UK for tax purposes.
The London-based music royalty investment company applied to become an investment trust company to mitigate the recently increased scope of Guernsey's economic substance rules. These now apply to Guernsey entities, including Guernsey tax-exempt vehicles, that are self-managed collective investment schemes.
Hipgnosis said it will be exempt from UK tax on chargeable gains, but will be liable for corporation tax on its income.
"The company should, in practice, be exempt from UK corporation tax on dividend income received, provided that such dividends, whether from UK or non UK companies, fall within one of the 'exempt classes' in Part 9A of the Corporation Tax Act 2009," said Hipgnosis.
Shares in Hipgnosis Songs Fund were down 0.1 at 125.40 pence in London on Thursday.
By Zoe Wickens; [email protected]
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