Section 1154: Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”
3292.This section defines “51% subsidiary”, “75% subsidiary” and “90% subsidiary” in terms of beneficial ownership of the subsidiary’s ordinary share capital. It is based on section 838(1), (2) and (3) of ICTA.
3293.In the case of the definitions of “51% subsidiary” and “75% subsidiary” (but not “90% subsidiary”), “indirect ownership”counts towards meeting the test. Indirect ownership means the attribution to one company (“A”) of all or part of the ordinary share capital in the subsidiary in question held by a company in which A has an interest. The remainder of the Chapter sets out how such indirect ownership is identified and quantified.
