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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Substantial shareholdings exemption: the trading company/group/subgroup requirements - when are non-trading activities substantial - expenses incurred, or time spent, by officers and employees of the company in undertaking its activities


If a substantial proportion of the expenses of a company were to be incurred on non-trading activities then, on this measure, the company would not be a trading company. Or a company may devote a substantial amount of its staff resources, by time or costs incurred, to non-trading activities.