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Home / Simons-Taxes /IHT, trusts and estates /Part I7 Special reliefs /Division I7.1 Business property relief (BPR) /Meaning of relevant business property / I7.115 BPR for holding companies and groups of companies
Commentary

I7.115 BPR for holding companies and groups of companies

IHT, trusts and estates

Shares or securities of a company wholly or mainly making or holding investments will be eligible for relief where the they are shares or securities of a company whose business is mainly that of being a holding company of one or more companies whose business is not dealing in securities etc or holding investments1.

For the meaning of 'wholly or mainly' and 'making or holding investments' see I7.112.

For the purposes of these provisions a company and all its subsidiaries are members of a group and 'holding company' and 'subsidiary' have the same meanings as in the Companies Act 2006, s 1159 and Schedule 6 to that Act2. A holding company is defined as a holding company in relation to another company if that other company is its subsidiary.

A company is a 'subsidiary' of another company, its 'holding company', if that other company:

  1. Ìý

    •ÌýÌýÌýÌý holds a majority of the voting rights in it, or

  2. Ìý

    •ÌýÌýÌýÌý is a member of it and has the right

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Web page updated on 17 Mar 2025 16:43