Commentary

D8.319 Qualifying issuing companies—partnerships and joint ventures requirement

Corporate tax
Corporate tax | Commentary

D8.319 Qualifying issuing companies—partnerships and joint ventures requirement

Corporate tax | Commentary

D8.319 Qualifying issuing companies—partnerships and joint ventures requirement

Neither the issuing company nor any of its qualifying subsidiaries may be a member of either a non-qualifying partnership or a non-qualifying joint venture at any time during the qualification period1. The purpose of this rule is to prevent an issuing company circumventing the trading activities requirement (see D8.323) by use of a partnership or joint venture.

A non-qualifying partnership is one that:

  1.  

    (a)     carries on the relevant trade (defined below)

  2.  

    (b)     where the other partners include at least one other company; and

  3.  

    (c)     where the same person (or persons) beneficially own more

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