Income Tax Act 2007 section 257DN

The property managing subsidiaries requirement

Section 257DN sets out the requirements that must be met by any property managing subsidiary of a company issuing shares under the Seed Enterprise Investment Scheme (SEIS) during the relevant compliance period (period B).

• Any property managing subsidiary the issuing company holds during period B must be a qualifying 90% subsidiary of that company
• A property managing subsidiary is one whose business consists wholly or mainly of holding or managing land, or assets deriving their value from land
• Assets deriving value from land include shareholdings in land-related companies, interests in settled property linked to land, and options, consents or embargoes affecting land disposal
• The definition captures both direct and indirect connections to land value, ensuring comprehensive coverage of property-related activities