If at any time in Period B (see ¶323-030) the issuing company has any subsidiaries, they must all be ‘qualifying subsidiaries’ (ITA 2007, s. 187). (There is, however, an additional requirement in respect of subsidiaries who hold or manage land or property which derives its value from land; see ¶323-390.)

A ‘qualifying subsidiary’ is one in respect of which the following conditions are satisfied:

it is a ‘51% subsidiary’ of the relevant company (meaning that more than 50% of its ordinary share capital is owned directly or indirectly by the relevant company (CTA 2010, s. 1154(2) as applied by ITA 2007, s. 989));

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