STSM042475 - Exemptions and reliefs: reliefs: Section 77A 바카라 사이트� Example Transaction A (바카라 사이트淧articular Person바카라 사이트�)
Example 바카라 사이트� A 바카라 사이트淧articular Person바카라 사이트� obtains control
Four shareholders own 25% each of three trading companies. An agreement is reached with a third-party buyer, who wants to acquire 80% of the value of the three companies.
For commercial reasons the third-party buyer insists on purchasing 80% of a group structure rather than 80% of the individual companies.
To enable this, the existing shareholders of the three target companies insert a new holding company (the acquiring company). Following a share for share exchange between the acquiring company and the shareholders of the target companies, the third-party buyer purchases 80% of the issued share capital in the acquiring company.
Assuming all the other conditions for s.77 FA1986 relief are met the 바카라 사이트渄isqualifying arrangements바카라 사이트� are not the share exchange itself. The 바카라 사이트渄isqualifying arrangements바카라 사이트� (see STSM042460) are the agreement (in existence at the time of the share exchange) for the third-party buyer to purchase 80% of the acquiring company.
In this example there is a 바카라 사이트減articular person바카라 사이트� identified (the third-party buyer) who will, under the arrangements, take control of the acquiring company. Therefore, relief under s.77 FA1986 is not available.