CG17953n - Taper relief: trading company and holding company of a trading group - investments in joint venture companies

Where a company has a qualifying shareholding in a joint venture company (as defined in TCGA92/SchA1 Para23, see CG17952) then, provided the joint venture company is not in the same group as the company,

• the holding of any shares or securities that the company holds in the joint venture company is disregarded, and
• the company is treated as carrying on a proportion of the activities of the joint venture company equal to the proportion of that company's ordinary share capital it holds

in determining whether: (a) the company is a trading company, (b) a group that the company is a member of is a trading group, and (c) the company is the holding company of a trading group.