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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Determining the worldwide group

  • Section 473 Meaning of “a worldwide group”, “ultimate parent” etc
  • Section 474 Interpretation of section 473: “relevant entity”
  • Section 475 Meaning of “non-consolidated subsidiary” and “consolidated subsidiary”
  • Section 476 Continuity of identity of a worldwide group through time
  • Section 477 Treatment of stapled entities
  • Section 478 Treatment of business combinations
  1. Determining the worldwide group
  2. Treatment of business combinations

Section 478 | Treatment of business combinations

From legislation.gov.uk

(1)This section applies where two entities—

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

(b)are treated under international accounting standards as a single economic entity by reason of being a business combination achieved by contract.

(2)This Part has effect as if—

(a)the two 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)In this section “business combination” has the meaning given by international accounting standards.

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