CTM80535 - Consortia: group relief: 90% subsidiary

A trading company which is a 90% subsidiary of a holding company owned by a consortium may itself be a company owned by the consortium ( CTM80530). Such a subsidiary is a 90% subsidiary if the holding company:

• holds not less than 90% of the subsidiary company's ordinary share capital as defined in ICTA88/S832,

and

• additionally (see ICTA88/S413 (7)) is beneficially entitled to not less than 90% of:

and

The detailed rules in the second bullet above are in ICTA88/SCH18. The description of how these apply is in CTM81000 onwards.

Where the provisions in the second bullet above interrupt an existing consortium arrangement during an accounting period, the provisions of ICTA88/S403A apply ( CTM80215).