CTM21530 | ACT: FID: international headquarters companies (IHC): foreign held
From HM Revenue & Customs · Company Taxation Manual
ICTA88/S246S (10)
For the purposes of the tests in , a company was a foreign held company in an accounting period if throughout the accounting period:
at least 80% of the company’s share capital was owned by persons who were not UK resident at any time in the accounting period,
or
the company was wholly owned by another company, and at least 80% of that other company’s share capital was owned by persons who were not UK resident at any time in the accounting period.