Corporation Tax Act 2010 section 83

The property managing subsidiaries requirement

Section 83 sets out the requirement that any property managing subsidiary of the company must be a qualifying 90% subsidiary of that company.

• Any subsidiary that manages property on behalf of the company must meet a minimum ownership threshold.
• The subsidiary must be a "qualifying 90% subsidiary", meaning the parent company must hold at least 90% of it.
• This requirement must be met throughout the relevant qualifying period specified elsewhere in the legislation.
• The definitions of "property managing subsidiary" and "qualifying 90% subsidiary" are drawn from the Income Tax Act 2007.