CG73996V | UK property rich collective investment vehicles: Key definitions and terms: Meaning of 'wholly' and 'almost wholly owned'

Paragraph 40 of Schedule 5AAA to TCGA 92

A company (including a deemed company under para 4 of Schedule 5AAA) is “wholly owned” if a person or persons have a 100% investment in the company. Investment is measured using the rules in paragraph 9 of Schedule 1A TCGA 92 (see CG73938), but assuming that the level is 100% rather than 25%. Where necessary, a CIV is considered a person in terms of whether paragraph 9 applies to test whether they have a 100% investment (such as for a limited partnership under paragraph 12(3) of Schedule 5AAA (see CG73998S).

Similarly, a company is “wholly owned or almost wholly owned” if a person or persons have a 99% or greater investment in that company.