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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Shadow ACT: definition of a group: additional tests for parent companies

SI1999/358, Reg. 6(2)(c)

The parent company is to be treated as not being the owner of any share capital, which it owns:

  • directly in a company, if a profit on sale of the shares would be treated as a trading receipt,
  • indirectly and which is owned directly by a body corporate for which a profit on sale of the shares would be treated as a trading receipt, or
  • directly or indirectly in a body corporate not resident in the UK.