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Corporation Tax Act 2010

Section 1164: More about the meaning of “holding in a company”

3312.This section gives more information about how to interpret a holding in a company for the purposes of condition E. It is based on section 842(1A), (3) and (4) of ICTA.

3313.Subsections (1) and (2) deal with certain cases involving a scheme of reconstruction. The newly issued shares or securities in the first company are treated under subsection (2) as forming part of the existing holding of shares or securities in the second company. Since the shares or securities are issued for no consideration there is no enlargement of the holding as defined in section 1163(2).

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