# Taxation (International and Other Provisions) Act 2010, Section 64: Meaning of “dividend-paying chain” of companies


(1) For the purposes of sections 65, 67 and 70 there is a dividend-paying chain if—
(a) condition A is met, and
(b) one of conditions B to D is met.
(2) Condition A is that a company (“the second company”) pays a dividend to another company (“the first company”).
(3) Condition B is that there is a third company which is a 10% associate of, and pays a dividend to, the second company.
(4) Condition C is that there is a succession of companies consisting of—
(a) a third company which is a 10% associate of, and pays a dividend to, the second company, and
(b) a fourth company which is a 10% associate of, and pays a dividend to, the third company.
(5) Condition D is that there is a succession of companies consisting of—
(a) a third company which is a 10% associate of, and pays a dividend to, the second company, and
(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.
(6) For the purposes of this section, a company (“X”) is a 10% associate of another company (“H”) if H—
(a) controls directly or indirectly, or
(b) is a subsidiary of a company which controls directly or indirectly,
at least 10% of the voting power in X or at least 10% of the ordinary share capital of X.
(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.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/64 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-64
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

