PART 2Residential property developer tax

Miscellaneous

48Groups

(1)

In this Part, other than in Schedule 7, “group” means two or more companies which together meet the following condition.

(2)

The condition is that one of the companies is—

(a)

the ultimate parent of each of the other companies, and

(b)

is not the ultimate parent of any other company.

(3)

A company (“A”) is the “ultimate parent” of another company (“B”) if—

(a)

A is the parent of B, and

(b)

no company is the parent of both A and B.

(4)

A company (“A”) is the “parent” of another company (“B”) if—

(a)

B is a 75% subsidiary of A,

(b)

A is beneficially entitled to at least 75% of any profits available for distribution to equity holders of B, or

(c)

A would be beneficially entitled to at least 75% of any assets of B available for distribution to its equity holders on a winding up.