Taxation of Chargeable Gains Act 1992 section 24 of Schedule 7AC

Meaning of "joint venture company" and "qualifying shareholding"

Section 24 of Schedule 7AC defines what constitutes a "joint venture company" and what it means to hold a "qualifying shareholding" in such a company, for the purposes of the substantial shareholdings exemption.

  • A joint venture company must be a trading company (or holding company of a trading group or subgroup) where five or fewer persons hold 75% or more of its ordinary share capital, with group members counted as a single person.
  • A company outside a group has a qualifying shareholding if it holds 10% or more of the joint venture company's ordinary share capital.
  • A company within a group has a qualifying shareholding if it holds any ordinary share capital and the group members collectively hold 10% or more of the joint venture company's ordinary share capital.
  • These definitions determine eligibility for the substantial shareholdings exemption in the context of joint venture arrangements.

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