CTM60730 | Close companies: close investment holding companies: wholly or mainly
From HM Revenue & Customs · Company Taxation Manual
In order to be excluded from close investment-holding company status, the relevant company must exist throughout the accounting period wholly or mainly for the excluded purpose. Where, for example, a company has substantial income from sources other than (or as well as) trading or property investment, its purpose may not be clear-cut. There will also be cases where the amount and source of income is inconclusive as a test of purpose. In such cases, a common sense approach is needed, and a review of all the facts should enable you to make a decision, for example:
What are the relative levels, and sources, of income?
What activities has the company undertaken?
What do minutes of meetings and other documents reveal about the company’s business?
What are the assets (nature and amount) and to what uses have they been put?