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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
Updated
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EIS: income tax relief: the issuing company: property managing subsidiaries requirement

ITA07/S188

FA04 introduced a requirement that if the company has a subsidiary whose business consists wholly or mainly of holding or managing land or property deriving its value from land, that subsidiary (termed a ‘property managing subsidiary’) must be a qualifying 90% subsidiary of the company.

References in the legislation to property deriving its value from land include:

  • any shareholding in a company deriving its value directly or indirectly from land
  • any interest in settled property deriving its value directly or indirectly from land
  • any option, consent or embargo affecting the disposition of land

For the definition of ‘qualifying 90% subsidiary’ see VCM13080.