BLM80337 | Sale of lessor companies and similar arrangements: establishing change of ownership: consortia: 75% subsidiaries of companies owned by a consortium

CTA2010/S397/S398

This guidance applies to transactions where the relevant day falls on or after 9 December 2009.

Where the lessor company is a 75% subsidiary of a holding company owned by a consortium the ownership proportion is determined by reference to shareholdings in the holding company.

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In this example A Ltd is the lessor company. It is a 100% subsidiary of D Ltd. D Ltd is a holding company owned by a consortium. The ownership proportion is determined by reference to the relationship between the holding company, D Ltd, and the member of the consortium, E Ltd or F Ltd. The ownership proportion is therefore 50% in the case of both E Ltd and F Ltd.