Application of exemptions and reliefs: Group Relief
English Partnerships (EP) and English Limited Partnerships (ELP)
A Ltd owns 100% of the issued share capital of B Ltd and C Ltd.
B Ltd and C Ltd own a 50% each partnership interest in ‘The Partnership’.
The partnership owns 100% of the issued share capital in E Ltd and F Ltd.
Where ‘The Partnership’ in the structure above is an English Partnership (EP) or an English Limited Partnership (ELP).