Section 477 | Treatment of stapled entities ^F1

(1)This section applies where two or more entities—

(a)would, apart from this section, each be the ultimate parent of a worldwide group, and

(b)are stapled to each other.

(2)This Part has effect as if—

(a)the entities were consolidated subsidiaries of another entity (the “deemed parent”), and

(b)the deemed parent fell within section 473(1)(a) (conditions for being the ultimate parent of a worldwide group).

(3)For the purpose of this section an entity (“entity A”) is “stapled” to another entity (“entity B”) if, in consequence of the nature of the rights attaching to the shares or other interests in entity A (including any terms or conditions attaching to the right to transfer the interests), it is necessary or advantageous for a person who has, disposes of or acquires shares or other interests in entity A also to have, dispose of or acquire shares or other interests in entity B.