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HMRC internal manual

Company Taxation Manual

Particular topics: company winding up TAAR: condition A

ITTOIA05/S396B/404A (2)


For the purpose of ITTOIA05/S396B/404A, a person has a 5% interest in a company if:

  • The individual holds at least 5% of the ordinary share capital of the company, and
  • The individual can exercise at least 5% of the voting rights in the company by virtue of that holding.


Ordinary share capital is defined at ITA07/S989.  See ETASSUM33070