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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: property managing subsidiaries requirement: introduction

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

The property managing subsidiaries requirement is set out at ITA07/S141. It is simply that any property managing subsidiary which the company has must be a qualifying 90% subsidiary of the company. The terms ‘property managing subsidiary’ and ‘qualifying 90% subsidiary’ are defined at ITA07/S188 and 190 respectively.