1. If a UK incorporated SME has its premises in the UK and over the years the level of consulting services provided to customers has moved from being carried out mainly in the UK to mainly overseas, whilst I understand that may previously have denied the use of an EMI scheme to incentivise key employees, is the recent Budget BN13 saying that an EMI scheme may now apply if the company has its offices in the UK which qualify as a permanent establishment not withstanding that the activities of the company are carried out mainly overseas by employees/subcontractors?
2. Paragraph 5 of BN13 refers to the current legislation being that in the case of a parent company "at least one company in the group must be carrying on a 'qualifying trade' wholly or mainly in the UK". Does this mean that if a company provided services to its customers both in the UK and overseas but mainly overseas, and following a commercial restructuring, it decided to set up a new holding company and a new subsidiary and transfer the overseas activities to the new subsidiary, that the shares in the parent company would then qualify under EMI ? Ie even though the groups activities taken as a whole may be mainly overseas, provided at least one subsidiary's activities were wholly or mainly in the UK then that would qualify the EMI to apply to the holding company's shares ?
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