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SCHEDULES

SCHEDULE 17U.K.Large businesses: notification of uncertain tax treatment

PART 1U.K.Key definitions

“Group”U.K.

3(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.