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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Effect of group ratio (blended) election

  • Section 401 Effect of group ratio (blended) election on group ratio percentage
  • Section 402 Effect of group ratio (blended) election on group ratio debt cap
  • Section 403 Calculations under sections 401 and 402: investor worldwide groups
  • Section 404 Meaning of “investor”, “related party investor” and investor's “share”
  1. Effect of group ratio (blended) election
  2. Meaning of “investor”, “related party investor” and investor's “share”

Section 404 | Meaning of “investor”, “related party investor” and investor's “share”

From legislation.gov.uk

(1)An entity is an “investor” in a worldwide group if it has an interest in the ultimate parent of the group that entitles it to a proportion of the profits or losses of the group.

(2)An investor in a worldwide group is a “related party investor” of the group in relation to a period of account of the group if, throughout the period, it is a related party of the ultimate parent of the group.

(3)The “share” of an investor in a worldwide group, in relation to a period of account of the group, is the proportion (expressed as a percentage) of the profits or losses of the group that arise in the period to which the investor is entitled by virtue of the investor's interest in the group's ultimate parent.

(4)This section has effect for the purposes of this Part.

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