SCHEDULE 10Group relief

PART 4Interpretation

When is a company a subsidiary of another company?

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A company (A) is the 75% subsidiary of another company (B) if B—

(a)

is beneficial owner of not less than 75% of the ordinary share capital of A,

(b)

is beneficially entitled to not less than 75% of any profits available for distribution to equity holders of A, and

(c)

would be beneficially entitled to not less than 75% of any assets of A available for distribution to its equity holders on a winding-up.