Taxation (International and Other Provisions) Act 2010 (c. 8)

Part 7 Tax treatment of financing costs and income

CHAPTER 5 Intra-group financing income where payer denied deduction

300 Meaning of “relevant associate”

For the purposes of this Chapter, the payer is a “relevant associate” of the recipient if—

(a) the payer is a parent of the recipient,

(b) the payer is a 75% subsidiary of the recipient, or

(c) the payer is a 75% subsidiary of a parent of the recipient.