# Taxation (International and Other Provisions) Act 2010, Section 371RG: Companies in which a UK resident company has more than a 50% investment


(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).
(2) A person (“P”) is an “associated enterprise” in relation to a UK resident company if—
(a) P directly or indirectly has a 25% investment in the company (or vice versa), or
(b) another person directly or indirectly has a 25% investment in each of P and the company.
(3) Section 259ND (meaning of “50% investment” and “25% investment”) applies for the purposes of determining for the purposes of this section—
(a) whether a person has “more than a 50% investment” in another person, and
(b) whether a person has a “25% investment” in another person,
and, 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).

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/371RG (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371RG
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.