Corporation Tax Act 2010 section 719

Meaning of "change in the ownership of a company"

Section 719 defines what constitutes a "change in the ownership of a company" for the purposes of Part 14 of the Corporation Tax Act 2010, which restricts the use of losses and other amounts following such a change.

• A change in ownership occurs if a single person acquires a holding of more than half the ordinary share capital of the company
• A change also occurs if two or more persons each acquire holdings of at least 5% of the ordinary share capital which together exceed half the total ordinary share capital
• Where two or more persons acquire holdings that together exceed half the ordinary share capital, individual holdings below 5% are ignored unless they are additions to existing holdings and the combined old and new holdings reach at least 5%
• For the purposes of certain group relief provisions (Chapters 2A to 2E), a change in ownership also occurs where a share acquisition causes a group condition to be met between the company and another company that was not previously in the same group