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HMRC internal manual

Venture Capital Schemes Manual

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HM Revenue & Customs
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VCT: VCT qualifying holdings: property managing subsidiaries requirement

ITA07/S299

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

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 meaning of ‘qualifying 90% subsidiary’ see VCM55170.