Part 7Tax treatment of financing costs and income

CHAPTER 10Other interpretative F1and supplementary provisions

Annotations:
Amendments (Textual)
F1

Words in Pt. 7 Ch. 10 heading substituted (retrospectively) by Finance (No. 3) Act 2010 (c. 33), Sch. 5 paras. 29, 36(1)

339Meaning of “ultimate parent”

1

For the purposes of this Part, “ultimate parent”, in relation to a group, means an entity that—

a

is a member of the group,

F2b

is either—

i

a corporate entity that is not a limited liability partnership in relation to which section 1273(1) of CTA 2009 (limited liability partnerships) applies, or

ii

a relevant non-corporate entity,

c

is not a collective investment scheme or an entity that would be a collective investment scheme but for the fact that it is a body corporate, and

d

is not a subsidiary (whether direct or indirect) of an entity that meets each of the conditions in paragraphs (a) to (c).

2

In this section “collective investment scheme” has the meaning given by section 235 of FISMA 2000.