Commentary

D8.324 Qualifying issuing companies—trading activities requirement: qualifying trades

Corporate tax
Corporate tax | Commentary

D8.324 Qualifying issuing companies—trading activities requirement: qualifying trades

Corporate tax | Commentary

D8.324 Qualifying issuing companies—trading activities requirement: qualifying trades

For the purpose of the trading activities requirement in D8.323, a trade qualifies if it meets the following three conditions1:

  1.  

    •     it is carried on wholly or mainly in the UK

  2.  

    •     it is carried on commercially, with a view to making profits, and

  3.  

    •     it does not consist wholly or substantially of excluded activities (see D8.325)

Whether an activity is carried on wholly or mainly in the UK depends on the facts of the particular case. HMRC accept that if more than half of the activities are carried out in the UK

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