Own capital, own account
Anything else needs FSMA authorisation.
A holding holds its own participations. It is not an investment firm, and the difference requires authorisation.
A holding company holds interests in other companies with its own capital. An investment firm does something fundamentally different: it provides services in relation to other people's money — receiving orders, managing portfolios, advising on investments, placing instruments, accepting funds from the public. That second category requires authorisation from the Financial Services and Markets Authority, and performing it without authorisation is a serious matter rather than a technical oversight.
The distinction gets blurred because the vocabulary overlaps and because the word holding sounds like finance. Approaches arrive proposing that a holding take in money, manage a portfolio or let someone invest alongside it. Each of those would move the company from one category to the other. So the boundary goes on the front page: we hold our own participations, with our own capital, and nothing here is an offer of securities or an invitation to invest.
The second thing worth stating applies inside a group rather than outside it. Where a holding charges management fees to a company it owns, those fees must correspond to services genuinely rendered, by identifiable people, at a price that can be substantiated. Fees without that substance are regularly disallowed, and the consequence lands on the subsidiary that paid as much as on the holding that invoiced. Documenting the work is therefore not administrative diligence but the thing that makes the arrangement stand up — which is also why a directorship held by a company requires a named individual as permanent representative, carrying the same liability as if the seat were theirs personally.
Anything else needs FSMA authorisation.
The adjustment hits both companies.
The permanent representative is liable.
An enquiry costs nothing, and we will say quickly if it is outside our scope.