CG53113A - Substantial shareholdings exemption: the trading company/group/subgroup requirements - trade

TCGA92/SCH7AC/PARA20 & TCGA92/SCH7AC/PARA21 & TCGA92/SCH7AC/PARA22

The following are trades for the purposes of the Substantial Shareholding Exemption:

• anything that is a trade, profession or vocation within the meaning of the Income Tax Acts and is conducted on a commercial basis with a view to the realisation of profits (Paragraph 27 of Schedule 7AC TCGA 1992), and
• any Schedule A business (within the meaning of ITTOIA 2005) which consists in the commercial letting of holiday accommodation in the United Kingdom (section 241(3) TCGA 1992 as amended by paragraph 3 of Schedule 8 to Finance Act 2002).

Activities, such as farming, that are treated as a trade by CTA09/S36 and CAT10/S1125, are trades for the purposes of the Income Tax Acts.