Taxes Consolidation Act 1997 Schedule 10

Relief for investment in corporate trades: subsidiaries

Schedule 10 was deleted by Finance Act 2018 section 25(2)(h). It adapted the Business Expansion Scheme (BES) relief rules in Part 16 to cover situations where a qualifying company carried on its trade through one or more subsidiaries.

  • Shares issued by a qualifying company could be used to raise money for a qualifying trade carried on by a subsidiary, not just by the company itself.
  • The "connected person" restrictions that could deny or withdraw BES relief were extended to include connections with subsidiary companies.
  • The rules on receiving value from a company, which could reduce or withdraw relief, also applied where value was received from a subsidiary.
  • Revenue could request information about any arrangements under which a subsidiary might cease to be a qualifying subsidiary.

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