Taxes Consolidation Act 1997 section 600D

Qualifying subsidiary

Section 600D defines what constitutes a qualifying subsidiary for the purposes of angel investor relief.

• The subsidiary must be tax resident in the State, another EEA state or the UK, carry on (or intend to carry on) relevant trading activities from a fixed place of business in the State, and hold a valid tax clearance certificate.
• It must be a 51 per cent subsidiary of either the applicant company or the qualifying company, and no other person may have control of it.
• No arrangements may exist that could cause the ownership or control conditions to cease to be met.
• Where a company has qualifying subsidiaries, certain conditions for qualifying company status may be satisfied by a subsidiary rather than the company itself.