{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371RG",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371RG.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/371RG",
  "kind": "section",
  "number": "371RG",
  "heading": "Companies in which a UK resident company has more than a 50% investment",
  "text": "(1) If a UK resident company (whether alone or together with any associated enterprises) directly or indirectly has more than a 50% investment in a non-UK resident company, the non-UK resident company is to be taken to be a CFC (if it would not otherwise be).\n(2) A person (“P”) is an “associated enterprise” in relation to a UK resident company if—\n(a) P directly or indirectly has a 25% investment in the company (or vice versa), or\n(b) another person directly or indirectly has a 25% investment in each of P and the company.\n(3) Section 259ND (meaning of “50% investment” and “25% investment”) applies for the purposes of determining for the purposes of this section—\n(a) whether a person has “more than a 50% investment” in another person, and\n(b) whether a person has a “25% investment” in another person,\nand, accordingly, references in section 259ND to “X%” are to be read as references to more than 50% or to 25% (as appropriate) and references in that section to “X% or more” are to be read as references to more than 50% or to 25% or more (as appropriate).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 371RG inserted (with effect in accordance with s. 20(5)(6) of the amending Act) by Finance Act 2019 (c. 1), s. 20(4)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/371RG",
    "retrieved_at": "2026-10-29T09:10:17.008829+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."
}