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Taxation (International and Other Provisions) Act 2010

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[F1401Effect of group ratio (blended) election on group ratio percentageU.K.
This section has no associated Explanatory Notes

(1)Where a group ratio (blended) election (see paragraph 14 of Schedule 7A) has effect in relation to a period of account of a worldwide group (“the relevant period of account”), this Chapter applies subject to this section.

(2)Section 399 (meaning of “group ratio percentage”) does not apply for the purpose of determining the group ratio percentage of the group for the relevant period of account.

(3)Instead, the group ratio percentage of the group for the relevant period of account is determined by taking the following steps—

  • Step 1 For each investor in the group, multiply the investor's applicable percentage by the investor's share in the group.

  • Step 2 Add together the amounts found under Step 1.

(4)For the purposes of this section, an investor's “applicable percentage” is the highest of the following percentages—

(a)30%;

(b)the percentage determined under section 399;

(c)in the case of a related party investor that, throughout the relevant period of account, is a member of a worldwide group (“the investor's worldwide group”) other than that mentioned in subsection (1), the group ratio percentage of the investor's worldwide group for the relevant period of account.

(5)Subsection (6) applies where financial statements of the investor's worldwide group are drawn up in respect of one or more periods (“the investor's periods of account”) that are comprised in or overlap with (but are not coterminous with) the relevant period of account.

(6)The group ratio percentage of the investor's worldwide group for the relevant period of account is to be determined for the purposes of subsection (4)(c) by taking the following steps—

  • Step 1 Find the group ratio percentage of the investor's worldwide group for each of the investor's periods of account.

  • Step 2 Find the proportion of the relevant period of account that coincides with each of the investor's periods of account.

  • Step 3 For each of the investor's periods of account, multiply the group ratio percentage found under Step 1 by the proportion found under Step 2.

  • Step 4 Add together the amounts found under Step 3.]

Textual Amendments

F1Pt. 10: the existing Pt. 10 renumbered as Pt. 11 (except for ss. 375, 376 which are repealed), the existing ss. 372-374, 377-382 renumbered as ss. 499-507 and a new Pt. 10 (ss. 372-498) inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1, 10(1)(2)(a)(3) (with Sch. 5 paras. 27, 32-34)

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