Taxation of Chargeable Gains Act 1992 section Sch 7AC para 21

Meaning of "trading group"

Section Sch 7AC paragraph 21 defines what constitutes a "trading group" for the purposes of the substantial shareholdings exemption, setting out the types of activities that count as trading activities and how group members' activities are assessed collectively.

  • A trading group is one where at least one member carries on trading activities and the combined activities of all members do not include non-trading activities to a substantial extent
  • Trading activities include carrying on a trade, preparing to start a trade, taking steps to acquire or begin a trade, and acquiring a significant stake in an external trading company or holding company of a trading group
  • Activities aimed at acquiring a trade or a significant shareholding only qualify as trading activities if the acquisition or commencement happens as soon as reasonably practicable
  • Intra-group activities are disregarded because the group's members are treated as carrying on a single combined business

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