Corporation Tax Act 2010 section 720

Section 719: supplementary

Section 720 provides supplementary rules for determining whether a change in company ownership has occurred under section 719, including how to compare shareholdings at different points in time and how connected persons' holdings are aggregated.

• Shareholdings at any two points up to three years apart may be compared, and a holder at the later date is treated as having acquired whatever they did not hold at the earlier date, regardless of any transactions in between.
• Where shares have been issued or capital has been reorganised, comparisons may be made using percentage holdings of total ordinary share capital, so that an increase in percentage is treated as an acquisition of that percentage.
• To determine whether a person has acquired a holding of at least 5% (alone or when added to an existing holding), the acquisitions and holdings of connected persons must be aggregated as if they belonged to a single person.
• Shares acquired under a will or on intestacy are disregarded, as are unsolicited gifts of shares made without regard to the provisions of this Part of the Act.