For the purposes of paragraphs 20 and 27 a company is “above” the seller in the group structure if the seller, or another company that is above the seller in the group structure, is a 75% subsidiary of the company.

In this Part of this schedule—

• “control” is to be interpreted in accordance with sections 450 and 451 of the Corporation Tax Act 2010 (c.4) (but see paragraph 31),

• “relevant associated company”, in relation to the buyer, means a company that—

  1. a

     is a member of the same group as the buyer immediately before the buyer ceases to be a member of the same group as the seller, and

  2. b

     ceases to be a member of the same group as the seller in consequence of the buyer so ceasing.