Commentary

D8.315 Requirements for qualifying issuing companies

Corporate tax
Corporate tax | Commentary

D8.315 Requirements for qualifying issuing companies

Corporate tax | Commentary

Qualifying issuing companies

D8.315 Requirements for qualifying issuing companies

In order for an issuing company to be a qualifying issuing company, the following conditions must be satisfied1:

  1.  

    (a)     it must be unquoted (see D8.316)

  2.  

    (b)     it must be independent (see D8.317)

  3.  

    (c)     at least 20% of its ordinary share capital must be beneficially owned by independent individual-owners (see D8.318)

  4.  

    (d)     it must not be a member of certain partnerships or joint ventures with associated persons (see D8.319)

  5.  

    (e)     it must have only qualifying subsidiaries (see D8.320)

  6.  

    (f)     it must satisfy the gross assets requirement (broadly, for shares issued on

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