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HMRC internal manual

Venture Capital Schemes Manual

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HM Revenue & Customs
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Share loss relief: individual and corporate claimants: individual claimants: type of company invested in: qualifying trading company: condition A: the qualifying subsidiaries requirement: introduction

The qualifying subsidiaries requirement is one of the four requirements of Condition A at ITA07/S134, and Condition A is one the four conditions a company must meet in order for it to be a qualifying trading company.

The qualifying subsidiaries requirement is set out at ITA07/S140. It is simply that any subsidiary the company has must be a qualifying subsidiary, and ‘qualifying subsidiary’ is to be read in accordance with section 191.