Section 476 | Continuity of identity of a worldwide group through time

(1)This section applies for the purpose of determining whether a group of entities that constitutes a worldwide group at any time (“Time 2”) is the same worldwide group as a group of entities that constitutes a worldwide group at an earlier time (“Time 1”).

(2)The group at Time 2 is the same worldwide group as the group at Time 1 if and only if the entity that is the ultimate parent of the group at Time 2—

(a)was the ultimate parent of the group at Time 1, and

(b)was the ultimate parent of a worldwide group at all times between Time 1 and Time 2.