Income Tax Act 2007 Schedule 2 paragraph 43

The qualifying subsidiaries requirement

Section 140 sets out the qualifying subsidiaries requirement for share loss relief, but paragraph 43 of Schedule 2 provides a transitional rule disapplying it for older share issues.

• Section 140 imposes a qualifying subsidiaries requirement as a condition for share loss relief
• This requirement does not apply to shares issued before 6 April 1998
• The transitional rule recognises that earlier share issues were made under different legislative conditions
• For shares issued on or after 6 April 1998, the qualifying subsidiaries requirement applies in full