SCHEDULES
SCHEDULE 17Large businesses: notification of uncertain tax treatment
PART 1Key definitions
3“Group”
1
A company is a member of a group if—
a
another company is its 51% subsidiary, or
b
it is a 51% subsidiary of another company.
2
Two companies are members of the same group if—
a
one is a 51% subsidiary of the other, or
b
both are 51% subsidiaries of another company.
3
Sub-paragraph (4) applies where a company (“Q”)—
a
is a qualifying asset holding company for the purposes of Schedule 2 to this Act, and
b
is a member of a worldwide group, within the meaning given by section 473 of TIOPA 2010.
4
Another company is not a member of the same group as Q for the purposes of this Schedule if, by virtue of paragraph 42(2)(a) of Schedule 2 to this Act, that other company is not a member of the same worldwide group as Q for the purposes of Part 10 of TIOPA 2010 (corporate interest restriction).
5
Chapter 3 of Part 24 of CTA 2010 (meaning of 51% subsidiary) applies for the purposes of this Schedule as it applies for the purposes of the Corporation Tax Acts.