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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 - investments in Corporate Venturing Schemes (CVS)


Investments in shares made under the CVS are investments like any others and the holding of such shares is unlikely to count as a trading activity in its own right. However, the CVS works in such a way that a company that qualifies for CVS investment relief is unlikely to have more than the 20% non-trading activity that would stop it being a trading company for SSE purposes.