Corporation Tax Act 2010

1154 Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”

(1) Subsections (2) to (4) define, for the purposes of the Corporation Tax Acts, the circumstances in which a body corporate (“B”) is a 51% subsidiary, a 75% subsidiary or a 90% subsidiary of another body corporate (“A”).

(2) B is a 51% subsidiary of A if more than 50% of B’s ordinary share capital is owned directly or indirectly by A.

(3) B is a 75% subsidiary of A if at least 75% of B’s ordinary share capital is owned directly or indirectly by A.

(4) B is a 90% subsidiary of A if at least 90% of B’s ordinary share capital is owned directly by A.

(5) For the purposes of subsections (2) and (3) ordinary share capital is owned “directly or indirectly” by a body corporate if it is owned by it—

(a) directly,

(b) indirectly, or

(c) partly directly and partly indirectly.

(6) In this Chapter references to ownership are to be read as references to beneficial ownership.