Section 1154 Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”C1
United Kingdom
Subsections (2) to (4) define, for the purposes of the Corporation Tax Acts, the circumstances in which a body corporate (“B”) is a 51% subsidiary, a 75% subsidiary or a 90% subsidiary of another body corporate (“A”).
B is a 51% subsidiary of A if more than 50% of B's ordinary share capital is owned directly or indirectly by A.
B is a 75% subsidiary of A if at least 75% of B's ordinary share capital is owned directly or indirectly by A.
B is a 90% subsidiary of A if at least 90% of B's ordinary share capital is owned directly by A.
For the purposes of subsections (2) and (3) ordinary share capital is owned “directly or indirectly” by a body corporate if it is owned by it—
directly,
indirectly, or
partly directly and partly indirectly.
In this Chapter references to ownership are to be read as references to beneficial ownership.
Annotations
Modifications
- C1
S. 1154 modified by Income and Corporation Taxes Act 1988 (c. 1), Sch. 25 para. 12(3) (as amended) (with effect in accordance with s. 1184(1) of the amending Act) by 2010 c. 4, s. 1184(1), Sch. 1 para. 147(3) (with Sch. 2)
Notes on Chapter 3
Modifications
- C1
Pt. 24 Ch. 3 applied in part (with modifications) by 2010 c. 8, s. 345(7)-(10) (as substituted (with effect in accordance with s. 39(4) of the amending Act) by Finance Act 2014 (c. 26), s. 39(2))
- C2
Pt. 24 Ch. 3 applied (with modifications) (with effect in accordance with s. 161(2) of the amending Act) by Finance Act 2016 (c. 24), Sch. 19 para. 8(5)(6)
- C3
Pt. 24 Ch. 3 applied (with effect in accordance with s. 51 of the amending Act) by Finance Act 2022 (c. 3), s. 50(3)(5)(6)
- C4
Pt. 24 Ch. 3 applied (1.4.2022 in relation to relevant returns that are required to be made on or after that date) by Finance Act 2022 (c. 3), Sch. 17 para. 3(5)