EGL64100 | Election to treat a joint venture or group company with significant minority shareholders as transparent: introduction
From HM Revenue & Customs · Electricity Generator Levy Manual
As an alternative to the attribution rules described at EGL60000+, F(2)A23/S300 and F(2)A23/S301 provide the option to treat a joint venture company or a group company with at least one significant minority shareholder as being transparent for EGL purposes. The result is that the relevant company will be treated in a similar way to a partnership.
The ability to make an election is subject to conditions to ensure that all the affected participants or shareholders consent to the treatment.