Related Commentary  Related HMRC Manuals

177(1)  The provisions of this section apply where one company (“the first company”) has a holding in another company (“the second company”) and the following conditions are fulfilled–

(a)that the holding amounts to, or is an ingredient in a holding amounting to, 10 per cent of all holdings of the same class in the second company,

(b)that the first company is not a dealing company in relation to the holding,

(c)that a distribution is or has been made to the first company in respect of the holding, and

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