{
  "url": "https://openlegislation.uk/finance-act-2016/schedule-19/paragraph-50",
  "json_url": "https://openlegislation.uk/finance-act-2016/schedule-19/paragraph-50.json",
  "legislation": "ukpga/2016/24",
  "legislation_title": "Finance Act 2016",
  "legislation_url": "https://openlegislation.uk/finance-act-2016",
  "path": "schedule/19/paragraph/50",
  "kind": "paragraph",
  "number": "50",
  "heading": null,
  "text": "(1) A UK sub-group of a foreign group falls within this Part if—\n(a) the sub-group has persistently engaged in unco-operative behaviour (see paragraphs 36 to 38),\n(b) some or all of the unco-operative behaviour has caused there to be, or contributed to there being, two or more significant tax issues in respect of the sub-group or members of the sub-group which are unresolved (see paragraph 39), and\n(c) there is a reasonable likelihood of further instances of the sub-group engaging in unco-operative behaviour in a manner which causes there to be, or contributes to there being, significant tax issues in respect of the sub-group or members of the sub-group.\n(2) Paragraphs 36 to 40 apply in relation to a UK sub-group as they apply in relation to a UK group.\n(3) Paragraphs 41 to 45 apply in relation to the head of a UK sub-group of a foreign group that is a qualifying group at the material time as they apply in relation to the head of a UK group.\n(4) In the application of paragraph 41 in the case of a UK sub-group, sub-paragraph (4) has effect in relation to a UK sub-group as if for paragraphs (b) and (c) there were substituted—\n“(b) the identity of the sub-group is not to be regarded as altered by any change in its membership resulting from a relevant body—\n(i) becoming a 51% subsidiary of a member of the sub-group, or\n(ii) ceasing to be a 51% subsidiary of another member of the sub- group; and\n(c) if the sub-group becomes a UK sub-group of another foreign group, it is to be treated as if it were still a UK sub-group of the original foreign group.”\n(5) As applied by this paragraph, paragraphs 36 to 45 have effect as if references to a UK group (including in references to the head of a UK group or members of a UK group) were references to a UK sub-group.\n(6) In paragraphs 40, 41, 46, 47 and 49, references to a group (including in references to the head of a group or members of a group) include a UK sub-group.\n(7) In paragraph 46, references to the head of a UK group include the head of a UK sub-group.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [
    {
      "type": "words substituted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words substituted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words substituted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words substituted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "words renumbered as Sch. 19 para. 12(5)(a)",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "word inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    },
    {
      "type": "inserted",
      "affecting": "ukpga/2017/32",
      "affecting_title": "Finance (No. 2) Act 2017"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2016/24/schedule/19/paragraph/50",
    "retrieved_at": "2026-10-29T09:06:05.350093+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}