Paragraph 4

(1)

A company is a “related company”, for the purposes of this Part of this Schedule, if, at any time in the relevant period, it was a member—

(a)

of the same group as the taxpayer company,

(b)

of a consortium which at that time owned the taxpayer company, or

(c)

of the same group as a company which at that time was a member of a consortium owning the taxpayer company.

(2)

For the purposes of sub-paragraph (1)(a) two companies are members of the same group if—

(a)

one is the 51% subsidiary of the other, or

(b)

both are 51% subsidiaries of a third company.

(3)

For the purposes of sub-paragraph (1)(c), two companies are members of the same group if they are members of the same group of companies within the meaning of Part 5 of CTA 2010 (group relief).

(4)

For the purposes of this Part of this Schedule—

(a)

a company is a member of a consortium if it is a member of a consortium within the meaning of Part 5 of CTA 2010, and

(b)

a company is owned by a consortium if it is owned by a consortium within the meaning of that Part.

(5)

In this paragraph “51% subsidiary” has the meaning given by section 1154 of CTA 2010.