Part 7Tax treatment of financing costs and income

CHAPTER 10Other interpretative provisions

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,

(b)

is a corporate entity or a relevant non-corporate entity,

(c)

is not a subsidiary (whether direct or indirect) of a corporate entity or a relevant non-corporate entity, and

(d)

is not a collective investment scheme.

(2)

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