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Corporation Tax Act 2010

Section 942: Options that may be applied for the purposes of the ownership condition

2795.This section sets out various options that may be applied to see whether the ownership condition is met. It is based on section 344(2) and (3) of ICTA.

2796.Schedule 1 to the Interpretation Act 1978 defines “person” as including a body of persons corporate or unincorporate. Option 3 in subsection (1) therefore compresses “person or body of persons” in the tail words of section 344(2) of ICTA to “person”.

2797.Option 3 in subsection (1)is more focused on the final result than the tail words of section 344(2) of ICTA. But this difference is merely verbal.

2798.It is implicit in section 344(3)(c) of ICTA that ownership includes indirect ownership; subsection (6) makes this implication explicit and, therefore, applies to the whole of the section.

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