CTM18360 | Shadow ACT: definition of a group: additional tests for parent companies

From HM Revenue & Customs · Company Taxation Manual

SI1999/358 Reg6 (2)(c)

The parent company is to be treated as not being the owner of any share capital, which it owns

  • directly in a company, if a profit on sale of the shares would be treated as a trading receipt,

  • indirectly and which is owned directly by a body corporate for which a profit on sale of the shares would be treated as a trading receipt, or

  • directly or indirectly in a body corporate not resident in the UK.