Revenue Note for Guidance
This section provides for the conditions to be met in order for a subsidiary of a qualifying company to be a qualifying subsidiary
(1) As set out in section 490, a qualifying company may, upon certain conditions being satisfied , have one or more qualifying subsidiaries. In order for a subsidiary company to be a qualifying subsidiary it must satisfy the following conditions
In addition to the above the following conditions must also be satisfied -
(3) These conditions must be satisfied until the end of the relevant period, but will not be regarding as having been breached merely because, within that period, the holding company, or a subsidiary of that company, is wound up (or dissolved without winding up) for bona fide commercial reasons and not as part of a tax avoidance device. Where this happens the assets of the company must be distributed to its members before the end of the relevant period or within 3 years of the winding up, whichever is later.
Where a qualifying company has one or more subsidiaries in the relevant period, this Part applies subject to Schedule 10, which contains other detailed adjustments to cater for a company with qualifying subsidiaries.
Relevant Date: Finance Act 2021