4(1)A company is a “related company”, for the purposes of this Part of this Schedule, if, at any time in the relevant period, it was a member—U.K.
(a)of the same group as the taxpayer company,
(b)of a consortium which at that time owned the taxpayer company, or
(c)of the same group as a company which at that time was a member of a consortium owning the taxpayer company.
(2)For the purposes of sub-paragraph (1)(a) two companies are members of the same group if—
(a)one is the 51% subsidiary of the other, or
(b)both are 51% subsidiaries of a third company.
(3)For the purposes of sub-paragraph (1)(c), two companies are members of the same group if they are members of the same group of companies within the meaning of Part 5 of CTA 2010 (group relief).
(4)For the purposes of this Part of this Schedule—
(a)a company is a member of a consortium if it is a member of a consortium within the meaning of Part 5 of CTA 2010, and
(b)a company is owned by a consortium if it is owned by a consortium within the meaning of that Part.
(5)In this paragraph “51% subsidiary” has the meaning given by section 1154 of CTA 2010.