Commentary

D8.317 Qualifying issuing companies—independence requirement

Corporate tax
Corporate tax | Commentary

D8.317 Qualifying issuing companies—independence requirement

Corporate tax | Commentary

D8.317 Qualifying issuing companies—independence requirement

Throughout the qualification period, the issuing company must satisfy certain requirements as to its independence. It must not be a 51% subsidiary of another company. It must not be controlled by another company or by another company with persons connected with that other company1. Nor must there be any arrangements during the qualification period (other than allowing for the purchase of the company by a new company in circumstances where there is deemed to be no disposal2) by which the company might become so controlled3.

Control here means the power of a company to secure the

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