BLM80365 - Sale of lessor companies and similar arrangements: establishing change of ownership: exceptions to qualifying change of ownership - consortia
CTA2010/S396
It is possible for a qualifying change in ownership to occur without any true change in the economic ownership of the lessor company - company A.
The principal companies of A Ltd are F Ltd and Z Ltd. Shares in A Ltd are transferred by E Ltd to B Ltd. Both E Ltd and B Ltd are wholly owned by F Ltd so that the transfer is an intragroup transfer or reorganisation.
The transfer of shares in A Ltd would fall foul of section 394 CTA2010 because the relevant fraction 바카라 사이트“ the percentage of the ordinary share capital of A Ltd held by E Ltd 바카라 사이트“ is less at the end of the day than at the start of the day.
It is clear that there has been no change in the economic ownership of A Ltd - F Ltd still owns 50% of the shares in A Ltd but it now owns those shares via B Ltd rather than via E Ltd.
Section 396 CTA2010 offers an exception in the case of intra-group reorganizations so that there is no qualifying change of ownership when the percentage of the ordinary share capital of company A (A Ltd) owned directly or indirectly by the principal company remains the same. This is the case here.