Income Tax Act 2007 section 299

The property managing subsidiaries requirement

Section 299 requires that any property managing subsidiary of the relevant company must be a qualifying 90% subsidiary of that company, and defines what constitutes a property managing subsidiary and property deriving its value from land.

• Any property managing subsidiary of the relevant company must be a qualifying 90% subsidiary of that company
• A property managing subsidiary is one whose business consists wholly or mainly of holding or managing land, or property deriving its value from land
• Property deriving its value from land includes shareholdings, partnership interests, interests in settled property, and options, consents or embargoes affecting land
• The definition of land itself is not provided in the Act but relies on the standard definition in the Interpretation Act 1978

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