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HMRC internal manual

Company Taxation Manual

Particular topics: dividend-stripping: 10% holdings: aggregation

The holdings of the company and those of ‘connected persons’, require to be aggregated for the purpose of deciding whether there is a 10% holding of which the company’s own holding is an ‘ingredient’. Subject to the slight modification set outin ICTA88/S736 (4), the expression ‘connected persons’ has the same meaning as in ICTA88/S839 (see CG14580 onwards).