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The term 'trading group' is used for the requirements to be met by the target company (see D1.1031) for the SSE to apply.

For this purpose a group is as defined by TCGA 1992, s 170 (see D2.305), except that the definition is amended so that group includes the principal company and its 51% subsidiaries rather than 75% subsidiaries¹. Use of the TCGA 1992, s 170 definition means that the group includes both UK and non-UK resident subsidiaries.

A trading group is a group where one or more of the members carries on trading activities and where the activities of all the members do not include non-trading activities to any substantial extent². For this purpose the activities of the members of the group are treated as one business, and intra-group activities are disregarded³. Such intra-group activity includes⁴:

1. Ìý

   •ÌýÌýÌýÌý holding shares in other group companies

2. Ìý

   •ÌýÌýÌýÌý making loans to other group members

3. Ìý

   •ÌýÌýÌýÌý intra-group trading transactions

4. Ìý

   •ÌýÌýÌýÌý paying and receiving dividends,