Paragraph 71

In this Schedule—

• “arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable;

• “company” means any body corporate;

• “group”, in relation to a parent company, means that company and its 51% subsidiaries;

• “group company”, in relation to a parent company, means that company or any of its 51% subsidiaries;

• “parent company” means a company that has one or more 51% subsidiaries and “single company” means a company that does not;

• “option” means any right to acquire shares;

• “ordinary share capital” has the meaning given in section 832(1) of the Taxes Act 1988;

• “research and development” has the meaning given by section 837A of the Taxes Act 1988;

• “shares” includes stock; and

• “tax year” means a year of assessment.

Section 839 of the Taxes Act 1988 (connected persons) applies for the purposes of this Schedule.