Transfers of securities of original holding company or its subsidiaries
7(1)This paragraph applies where—
(a)there is a disposal of securities of the original holding company or any of its subsidiaries, and
(b)immediately before the disposal, the original holding company or (as the case may be) the subsidiary was a 51% subsidiary of the Crown.
(2)The degrouping provisions are not to apply by reason of the disposal or any agreement to make the disposal (if they otherwise would).
(3)For the purposes of this paragraph “51% subsidiary” has the same meaning as it has for the purposes of the Corporation Tax Acts (see Chapter 3 of Part 24 of the Corporation Tax Act 2010), but—
(a)the Crown is to be treated as a body corporate, and
(b)for the purpose of determining beneficial ownership the making of an agreement to make the disposal is to be ignored.