Treatment of entities stapled to corporate entities or relevant non-corporate entities
83(1)Where a corporate entity is stapled to another entity, the two entities are treated for the purposes of this Schedule as if—
(a)they were one entity, and
(b)that one entity were a corporate entity.
(2)Where a relevant non-corporate entity is stapled to another entity, the two entities are treated as if—
(a)they were one entity, and
(b)that one entity were a relevant non-corporate entity.
(3)For the purposes of this paragraph an entity (“entity A”) is “stapled” to another (“entity B”) if, in consequence of the nature of the rights attaching to the shares or other interests in entity A (including any terms or conditions attaching to the right to transfer the interests), it is necessary or advantageous for a person who has, disposes of or acquires shares or other interests in entity A also to have, to dispose of or to acquire shares or other interests in entity B.