Commentary

D8.309 Qualifying investing companies—relevant preference shares

Corporate tax
Corporate tax | Commentary

D8.309 Qualifying investing companies—relevant preference shares

Corporate tax | Commentary

D8.309 Qualifying investing companies—relevant preference shares

Holdings of relevant preference shares are ignored in determining whether an investing company controls, or has a material interest in, the issuing company (see D8.306, D8.308).

Meaning of 'relevant preference shares'

Relevant preference shares are defined by reference to four characteristics1, so that they broadly include shares that have the characteristics of debt, not equity. The first characteristic is that the shares must not carry any voting rights. Second, they must have been issued for wholly new consideration. New consideration means consideration not provided directly or indirectly out of the assets of a company; in

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