SCHEDULES
SCHEDULE 27 Foreign income dividends
International headquarters company
F14
1
Section 246S of that Act (conditions for treatment as international headquarters company) shall be amended as follows.
2
In subsection (3)
(wholly-owned subsidiary of foreign quoted parent company), in paragraph (a), for “wholly owned by” there shall be substituted “
a 100 per cent. subsidiary of
”
.
3
Subsection (8) (extension of subsection (3)) shall cease to have effect.
4
After subsection (10) there shall be inserted the following subsection—
10A
For the purposes of this section a company is a 100 per cent. subsidiary of another if and so long as it is a body corporate all of whose share capital would fall to be treated for the purposes of section 838 as owned directly or indirectly by the other and that other is a body corporate; but for this purpose references in that section to owning share capital shall be construed in accordance with subsection (12) below.
5
Subject to sub-paragraph (6) below, this paragraph has effect in relation to any accounting period ending after 28th November 1995.
6
Where—
a
this paragraph has effect under sub-paragraph (5) above in relation to an accounting period in which a dividend is paid, and
b
the immediately preceding period ended on or before 28th November 1995,
subsection (9) (requirement to be international headquarters company in the period before that in which a dividend is paid) shall have effect in the case of that dividend as if this paragraph also had effect in relation to that immediately preceding period.