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HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: the trading company/group/subgroup requirements - when are non-trading activities substantial - the company's history


The company’s history may be relevant.

For example, at a particular instant certain receipts may be substantial compared to total receipts but, if looked at on a longer timescale, they may not be substantial compared to other receipts over that longer period. Looked at in this context, therefore, a company might be able to show that it was a trading company over a period, even where that period may have included particular points in time when, for example, non-trade receipts amounted to a substantial proportion of total receipts.