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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Corporation Tax: change of ownership: companies with investment business: conditions


Section 677 is modelled on CTA2010/S673 (CTM06300 onwards).

It applies where there is a change in the ownership of an investment company (or ‘company with investment business’ for periods on or after 1 April 2004) and:

  • within the period of six years beginning three years before the change, there is a major change in the nature or conduct of the business, or
  • the change in ownership occurs after the scale of activities has become small or negligible and before any considerable revival of the business or
  • after the change there is a significant increase in the amount of the company’s capital (CTM08750).

For the purposes of Section 677:

  • change in ownership is defined in CTA2010/S719 (see CTM06340 and CTM06350).
  • a major change in the nature or conduct of the business includes a major change in the nature of the investments held, even if that change was the result of a gradual process which began before the period of six years within which the change has to take place.