Section 1082 — Corporation Tax Act 2010: Conditions for distributions within section 1076(a)

Conditions for distributions within section 1076(a) 1082 1 Condition E is that the shares mentioned in section 1076(a)—

a must not be redeemable, b must constitute the whole or substantially the whole of the distributing company's holding of the ordinary share capital of the subsidiary, and c must confer the whole or substantially the whole of the distributing company's voting rights in the subsidiary.

2 Condition F is that the distributing company must after the distribution be either—

a a trading company, or b the holding company of a trading group. But see subsections (3) and (4).

3 Condition F need not be met if the distributing company is a 75% subsidiary of another company.

4 Condition F need not be met if—

a the transfer mentioned in section 1076(a) relates to two or more 75% subsidiaries of the distributing company, and b the distributing company is dissolved without there having been after the distribution any net assets of the company available for distribution on a winding up or otherwise.