CTM76560 - Exchange differences: matching: shares in a UK subsidiary

Shares in a UK company are eligible assets provided:

  • that company is a 90% subsidiary of the company making the election, and
  • the subsidiary company has made a local currency election to compute the basic profits or losses of a trade (or part trade) which it carries on in the UK by reference to a currency other than sterling, (see CTM76200 onwards), and
  • the shares are not qualifying assets (see CTM73910).

The definition of ‘90% subsidiary' follows the definition in ICTA88/S838 except that the share capital may be owned directly or indirectly (Regulation 5 (7)(b) SI1994/3227).