Income Tax Act 2007 Schedule 2 paragraph 77

The property managing subsidiaries requirement

Paragraph 77 of Schedule 2 provides a transitional rule exempting shares or securities issued before 17 March 2004 from the property managing subsidiaries requirement when determining qualifying holdings.

• Section 299 imposes a property managing subsidiaries requirement on companies seeking to have their shares or securities treated as qualifying holdings
• This transitional provision disapplies section 299 for shares or securities issued before 17 March 2004
• The exemption means older holdings are not retrospectively caught by the property managing subsidiaries test
• Shares or securities issued on or after 17 March 2004 remain fully subject to the section 299 requirement