Sample matter · INV-DX-0142
HoldCo
Holding 100% of its operating company, OpCo.
Day of acquisition1 Jan 2025
Earliest qualifying sale1 Jan 2027in 216 days
Planned / likely sale30 Jun 2027
Headroom+5 months
VerdictBUILDOn track to keep the sale proceeds at €0 tax under the exemption.
The three testsall three, at once
01
Ownership
PassHoldCo holds 100% of OpCo directly — well above the 10% line.
02
Time
On trackMonth 16 of 24. Earliest qualifying sale 1 Jan 2027.
03
Substance
On trackA real person, a real place and real decisions, logged each quarter.
This week · needs attention
▲
Q1 2026 monitoring memo overdue — 31 Mar 2026
Tab E. Reconstructed proof weakens the history — close this first.
⚑
Governance decision for Q1 2026 due
Tab D — the owner decision and minutes for the quarter.