“arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable;

“company” means any body corporate;

“group”, in relation to a parent company, means that company and its 51% subsidiaries;

“group company”, in relation to a parent company, means that company or any of its 51% subsidiaries;

“parent company” means a company that has one or more 51% subsidiaries and “single company” means a company that does not;

“option” means any right to acquire shares;

“ordinary share capital” has the meaning given in section 832(1) of the Taxes Act 1988;

“research and development” has the meaning given by section 837A of the Taxes Act 1988;

“shares” includes stock; and

“tax year” means a year of assessment.