For the purposes of section 212C(5) C's “relevant percentage share” is C's percentage share in the profits or losses of the F2activity.

For this purpose C's percentage share in the profits or losses of F3an activity at any time is determined on a just and reasonable basis.

In making that determination regard must be had, in particular, to any matter that would be taken into account in determining under section 1262 of CTA 2009 (but without regard to sections 1263 and 1264 of that Act) the company's share at that time in the profits or losses of the F4activity.