Related Commentary  Related HMRC Manuals

809VD(1)  Condition A is that the target company is–

(a)an eligible trading company,

(b)an eligible stakeholder company,

(ba)an eligible hybrid company, or

(c)an eligible holding company.

809VD(2)  A company is an “eligible trading company” if–

(a)it is a private limited company,

(b)it carries on one or more commercial trades or is preparing to do so within the next 5 years, and

(c)carrying on commercial trades is all or substantially all of what it does (or of what it is reasonably expected to do once it begins trading).

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