Corporation Tax Act 2010 section 712

Meaning of "a major change in the nature or conduct of a trade or business"

Section 712 defines what constitutes "a major change in the nature or conduct of a trade or business" for the purposes of the unpaid corporation tax recovery rules in section 711(4).

  • A major change includes significant shifts in the type of property dealt in, services provided, customers, outlets or markets, as well as a switch between trading company and investment company status
  • For investment companies, a major change in the nature of investments held also qualifies as a major change in the nature or conduct of the business
  • Changes that occur gradually through a series of transfers are still caught by this definition — there is no need for a single dramatic event
  • A company whose main business is holding shares or securities in 90% subsidiary trading companies is not treated as an investment company for these purposes

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