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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

Remittance Basis: Exemptions: Business investment relief: Condition A - eligible stakeholder company (s809VD(3) ITA2007)

An eligible stakeholder company is a private limited company which;

  • exists wholly for the purpose of making investments in eligible trading companies [see RDRM34345] ignoring minor or incidental purposes and
  • must actually hold at least one investment in an eligible trading company or be preparing to do so within two years of the relevant event [see RDRM34320].