CG63540 - Investors’ Relief: Trading Company

TCGA92/S169VV

For the purposes of IR, a “trading company” and “the holding company of a trading group” have the same meaning as in s165A (see CG64055).

A company is not regarded as ceasing to be a trading company or a holding company of a trading group merely because the company (or any subsidiaries) are in administration or receivership or where a resolution has been passed or an order made for the winding up of the company (or any subsidiaries). This only applies where the above events are for genuine commercial reasons and not where it is part of a scheme or arrangement where the main purpose is to avoid tax.

See CG63500 for a general description of the relief and the layout of the guidance.