Either the company or at least one of its qualifying subsidiaries must exist for the purpose of carrying on a qualifying trade. For a trade to be a qualifying trade, it must be conducted on a commercial basis and with a view to the realisation of profits – see the guidance at BIM85705 and BIM85710).

In addition, the trade must not consist wholly or as to a substantial part in the carrying on of ‘excluded activities’ – see VCM3000+.

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