51(1)A UK company falls within this Part if—U.K.
(a)the company has persistently engaged in unco-operative behaviour (see paragraphs 36 to 38),
(b)some or all of the unco-operative behaviour has caused there to be, or contributed to there being, two or more significant tax issues in respect of the company which are unresolved (see paragraph 39), and
(c)there is a reasonable likelihood of further instances of the company engaging in unco-operative behaviour in a manner which causes there to be, or contributes to there being, significant tax issues in respect of the company.
(2)Paragraphs 36 to 39 apply in relation to a company as they apply in relation to a UK group.
(3)Paragraphs 41 to 45 apply in relation to a company as they apply in relation to the head of a UK group.
(4)As applied by this paragraph, paragraphs 36 to 39 and 41 to 45 have effect as if references to a UK group, the head of a UK group or a member of a UK group were references to a company.
(5)Paragraph 47 applies in relation to a company as it applies in relation to a member of a group.
(6)Paragraph 49 applies in relation to a company as it applies in relation to a group.
(7)As applied by this paragraph, paragraphs 47 and 49 have effect as if references to a group, the head of a group or a member of a group were references to a company.