Fattorini Ltd v Inland Revenue Commissioners A holding company owned a part of the shares of 3 operative companies —ie, companies which actually carried on the trading with which they were all concerned. In 1936, the holding company purchased all the remaining shares in the 3 operative companies. In order to provide the purchase money, the holding company charged all the shares to the bank, and covenanted to pay to the bank all dividends received in respect of the shares so charged.