Define: Qualifying Company

a company in which a Shareholder or Trustee(s) holds the entire issued share capital and over which that Shareholder or Trustee(s) exercises control (within the meaning of section 1124 of the CTA 2010);

a company in which a Shareholder or Trustee(s) holds the entire issued share capital and over which that Shareholder or Trustee(s) exercises control (within the meaning of section 1124 of the CTA 2010);.

Relevant Circumstances

  • When tax or estate planning involves holding shares through a wholly-owned vehicle
  • If a shareholder is permitted to transfer shares to a controlled company
  • Where section 1124 CTA 2010 control tests determine eligibility

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