{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-64",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-64.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/64",
  "kind": "section",
  "number": "64",
  "heading": "Meaning of “dividend-paying chain” of companies",
  "text": "(1) For the purposes of sections 65, 67 and 70 there is a dividend-paying chain if—\n(a) condition A is met, and\n(b) one of conditions B to D is met.\n(2) Condition A is that a company (“the second company”) pays a dividend to another company (“the first company”).\n(3) Condition B is that there is a third company which is a 10% associate of, and pays a dividend to, the second company.\n(4) Condition C is that there is a succession of companies consisting of—\n(a) a third company which is a 10% associate of, and pays a dividend to, the second company, and\n(b) a fourth company which is a 10% associate of, and pays a dividend to, the third company.\n(5) Condition D is that there is a succession of companies consisting of—\n(a) a third company which is a 10% associate of, and pays a dividend to, the second company, and\n(b) two or more companies (the fourth and fifth companies, and so on) each of which is a 10% associate of, and pays a dividend to, the company above it in the succession.\n(6) For the purposes of this section, a company (“X”) is a 10% associate of another company (“H”) if H—\n(a) controls directly or indirectly, or\n(b) is a subsidiary of a company which controls directly or indirectly,\nat least 10% of the voting power in X or at least 10% of the ordinary share capital of X.\n(7) For the purposes of subsection (6), a company (“S”) is a subsidiary of another company (“P”) if P controls, directly or indirectly, at least 50% of the voting power in S.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/64",
    "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."
}