Corporation Tax Act 2010 section 85

The unquoted status requirement

Section 85 sets out the unquoted status requirement that must be met at the time shares are issued in order for a company to qualify for share loss relief.

• At the time the shares are issued, the company must be an unquoted company with no arrangements in place for it to cease being unquoted.
• There must be no arrangements for the company to become a subsidiary of another company through a share exchange where that new parent company is planned to lose its own unquoted status.
• Arrangements that only result in shares being listed on a stock exchange recognised or designated by an order made after the shares were issued are disregarded.
• "Arrangements" is broadly defined and includes any scheme, agreement or understanding, whether or not it is legally enforceable.