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HMRC internal manual

Venture Capital Schemes Manual

Share loss relief: individual and corporate claimants: individual claimants: type of company invested in: qualifying trading company: condition A: property managing subsidiaries requirement: how this requirement has changed over time

Before ITA 2007 came into effect, the property managing subsidiaries requirement was at ICTA88/S289(9) to (13). The conditions were the same for practical purposes, however before 6 April 2007 (when ITA 2007 came into effect) there was no provision for indirectly-held subsidiaries to be qualifying 90% subsidiaries.

For shares issued before 17 March 2004 the property managing subsidiaries requirement does not apply. A simpler set of conditions for a company to be a qualifying trading company apply to these shares: see VCM74330.