Corporation Tax Act 2010 Explanatory Notes

Section 1040: Determining whether interests as shareholders in a group are substantially reduced

3066.This section sets out how to determine whether the seller’s shareholding in the purchaser’s group is substantially reduced. It is based on section 222(2), (4), (5) and (6) of ICTA.

3067.The seller’s shareholding in the group, taken together with any shareholdings of the seller’s associates, must be no greater than 75% of what it was before the purchase of own shares took place.

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