Section 371RG | Companies in which a UK resident company has more than a 50% investment

(1)If a UK resident company (whether alone or together with any associated enterprises) directly or indirectly has more than a 50% investment in a non-UK resident company, the non-UK resident company is to be taken to be a CFC (if it would not otherwise be).

(2)A person (“P”) is an “associated enterprise” in relation to a UK resident company if—

(a)P directly or indirectly has a 25% investment in the company (or vice versa), or

(b)another person directly or indirectly has a 25% investment in each of P and the company.

(3)Section 259ND (meaning of “50% investment” and “25% investment”) applies for the purposes of determining for the purposes of this section—

(a)whether a person has “more than a 50% investment” in another person, and

(b)whether a person has a “25% investment” in another person,

and, accordingly, references in section 259ND to “X%” are to be read as references to more than 50% or to 25% (as appropriate) and references in that section to “X% or more” are to be read as references to more than 50% or to 25% or more (as appropriate).