Note that this scheme closed to new investment from 6 April 2023 onwards.
Key to an understanding of the rules relating to the eligibility of the SE are definitions of the following terms:
- Ìý
•ÌýÌýÌýÌý 'qualifying trade';
- Ìý
•ÌýÌýÌýÌý 'excluded activity': with supplementary glosses on property development, subsidised generation or export of electricity, and providing services or facilities for another business;
- Ìý
•ÌýÌýÌýÌý 'qualifying subsidiary'; and
- Ìý
•ÌýÌýÌýÌý '90% social subsidiary'.
Each of these terms is examined below.
Qualifying trade
A 'trade' in this context is to carry its ordinary meaning, as the extension to a venture in the nature of trade by ITA 2007, s 989 is specifically precluded1. This presumably excludes, inter alia, the body of case law concerning single, or very few, transactions (see Division B1.4).
In order to qualify, a trade must be conducted on a commercial basis and with a view to the realisation of profits. This is a tried and tested formula, especially in the context of trading losses (see, for instance,
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Web page updated on 17 Mar 2025 17:22