CG17921f - Taper relief: anti-avoidance rules - periods of inactivity - further situations where a company is active - holding companies and joint venture companies: Taper relief does not apply to disposals before 6 April 1998 or after 6 April 2008


TCGA92/SchA1/Para11A treats a company as active in certain specific situations where groups and/or joint ventures are involved. These are:

  • Where the company is the holding company of a group of companies that contains at least one active company; or,
  • Where the company has a qualifying shareholding in a joint venture company or is the holding company of a group of companies any member of which has a qualifying shareholding in a joint venture company.

By definition a joint venture company will be active, as it has to be a trading company or the holding company of a trading group, see CG17952.