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Jurisdiction(s):
United Kingdom
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Key definition
Investment definition

What does Investment mean? In practice, investment describes an asset or bundle of rights committed in a host state with the aim of generating a return. In investor-state work, the operative definition is treaty-specific: most bilateral investment treaties (BITs) and the Energy Charter Treaty use broad, asset-based lists covering, where applicable, tangible and intangible property located in the territory, shareholdings and other equity interests, contractual rights (including concessions), intellectual property, and loans or claims to money, subject to stated carve-outs. The ICSID Convention does not define investment; tribunals assess jurisdiction by the treaty text and case law, commonly considering a contribution of resources,...

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UK corporation tax: companies with investment business and investment companies—definitions, management expenses (Centrica), period attribution, reduction rules, anti-avoidance, clawback, and share loss relief

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Practice notes
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This Practice Note focuses on the precise tax meanings of a company with investment business and of an investment company, and not on broader, everyday uses of the term investment company (such as in relation to Family investment companies) or on other vehicles like investment trust companies. For those, see: Tax and investment trusts—overview.

What is a company with investment business?

A company with investment business is one whose activities consist, in whole or in part, of holding investments. This definition can be broken down as follows:

  • company—covers any body corporate or unincorporated association, but does not include partnerships, co-ownership schemes (as defined in section 235A of the Financial Services and Markets Act 2000 (see Practice Note: Authorised contractual schemes (ACSs))), local authorities and associations of local authorities (see Practice Note: What is the basis of corporation tax?)
  • business—the investment activity must amount to a business in fact...
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Web page updated on 22/05/2026

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