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HMRC internal manual

Venture Capital Schemes Manual

Share Loss Relief: definitions: S to Y

Seed Enterprise Investment Scheme (‘SEIS’) relief

See VCM30000 onwards.


The term is used to refer to one of two spouses who are living together (ITA07/S151(1)).

51% subsidiary

A company is a 51% subsidiary of another company if and so long as more than 50% of its ordinary share capital is owned directly or indirectly by that other company. (This definition is the same as that at CTA10/PT24/CH3, in section 1154, and is adopted by ITA07/S989).

Trading company

‘Trading company’ means a company other than an excluded company which is:

  1. a company whose business consists wholly or mainly of the carrying on of a trade or trades, or
  2. the holding company of a trading group.

Trading group

‘Trading group’ means a group the business of whose members, when taken together, consists wholly or mainly in the carrying on of a trade or trades.

For the purposes of this definition, any trade carried on by a subsidiary which is an excluded company is treated as not constituting a trade (ITA07/S151(7)). In relation to shares issued before 6 April 1998, trades carried on by non-UK resident companies are also to be discounted (ITA07/SCH2/PARA50(1)).

Year of the loss

This has the meaning given by ITA07/S131(1), that is to say the tax year in which the individual incurs the allowable loss for capital gains tax purposes on the disposal of shares in respect of which Share Loss Relief is due.