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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading How are the apportionments to be made?

  • Section 371QC The basic rules
  • Section 371QD Apportionments to be made in proportion to shareholding
  • Section 371QE Indirect shareholdings
  • Section 371QF Variable shareholdings
  • Section 371QG Anti-avoidance
  1. How are the apportionments to be made?
  2. Indirect shareholdings

Section 371QE | Indirect shareholdings

From legislation.gov.uk

(1)This section applies to the relevant interest of a relevant person (“R”) so far as R has that interest by virtue of holding, indirectly, ordinary shares in the CFC (“the relevant shares”).

(2)The percentage of the issued ordinary shares in the CFC represented by R's relevant interest (so far as this section applies to it) is given by the following formula—

Formula

P×S

where—

P is the product of the appropriate fractions of R and each of the share-linked companies through which R indirectly holds the relevant shares, other than the share-linked company which directly holds the relevant shares, and

S is the percentage of the issued ordinary shares in the CFC which the relevant shares represent.

(3)“The appropriate fraction”, in relation to any person who directly holds ordinary shares in a share-linked company, means that fraction of the issued ordinary shares in the share-linked company which the holding represents.

(4)If R has different indirect holdings of shares in the CFC (as in the case where different shares are held through different share-linked companies)—

(a)apply subsection (2) separately in relation to each holding (reading references to the relevant shares accordingly), and

(b)then add the separate results together to give the total percentage of the issued ordinary shares in the CFC represented by R's relevant interest (so far as this section applies to it).

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