Income Tax Act 2007 section 809FZJ

Significant interests

Section 809FZJ deals with how investments and disposals are treated when an investment scheme holds a controlling interest in a trading company or the holding company of a trading group.

• Any further investment made in a company after the scheme acquires a controlling interest is treated as if it were made at the time the controlling interest was first acquired.
• Any disposal of an investment in the company after the controlling interest is acquired is not recognised until the scheme makes a disposal that reduces its holding below a 40% interest.
• A "relevant disposal" is one that causes the investment scheme to cease holding a 40% interest in the company.
• When determining whether the controlling interest or 40% interest thresholds are met, share capital held by any associated investment scheme is aggregated with the main scheme's holdings.