½Û×ÓÊÓƵ

At the time of the issue of the relevant holding and at all times thereafter the relevant company (see E3.245 for definition) or a qualifying 90% subsidiary (see E3.252) must have been¹:

1. Ìý

   •ÌýÌýÌýÌý carrying on a qualifying activity, or

2. Ìý

   •ÌýÌýÌýÌý preparing to carry on a qualifying trade which, at the time the relevant holding was issued, was intended to be carried on by the company or a qualifying 90% subsidiary

Prior to 6 April 2011, there was also a requirement that the qualifying activity be wholly or mainly in the UK or that the trade was intended to be carried on wholly or mainly in the UK. In order to conform to EC guidelines, this is no longer the case (see E3.201).

The reference to a qualifying 90% subsidiary includes a reference to any company which is not a qualifying 90% subsidiary at the time the shares are issued, but which will be so at any future time².

Where the second bullet point above applies, the company