In order for a CoACS to remain eligible for seeding relief, it must also meet a portfolio test with respect to its holdings of either residential or non-residential property (Sch. 7A, para. 16(7)).

The portfolio test

With respect to residential property, the portfolio test is met at any time when:

the total chargeable consideration attributable to all the seeded interests held by the scheme is at least £100 million and

at least 100 of the seeded interests held by the scheme are interests in or over residential property

(Sch. 7A, para. 16(9)).

With respect to non-residential property, the portfolio test is met at any time when:

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