{
  "url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-A2/paragraph-14",
  "json_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-A2/paragraph-14.json",
  "legislation": "ukpga/1988/1",
  "legislation_title": "Income and Corporation Taxes Act 1988",
  "legislation_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988",
  "path": "schedule/A2/paragraph/14",
  "kind": "paragraph",
  "number": "14",
  "heading": null,
  "text": "(1) For the purposes of section 13AB and this Schedule a company and all its 51% subsidiaries form a group, and if any of those subsidiaries have 51% subsidiaries the group includes them and their 51% subsidiaries, and so on.\n(2) The question whether a company is a 51% subsidiary shall be determined in accordance with section 838, subject to the following provisions.\n(3) A company (“company A”) shall be treated for the purposes of this Schedule as if it were a 51% subsidiary of another company (“company B”) if company B has rights to, or in fact receives, more than 50% of the distributions made by company A.\n(4) For the purposes of this paragraph a company shall be treated as not being the owner—\n(a) of any share capital that it owns directly if a profit on the sale of the shares would be treated as a trading receipt of its trade, or\n(b) of any share capital that it owns indirectly and that is owned directly by a body corporate for which a profit on the sale of the shares would be treated as a trading receipt of its trade.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1988/1/schedule/A2/paragraph/14",
    "retrieved_at": "2026-10-29T09:49:54.309394+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."
}