Section 64 | Meaning of “dividend-paying chain” of companies

(1)For the purposes of sections 65, 67 and 70 there is a dividend-paying chain if—

(a)condition A is met, and

(b)one of conditions B to D is met.

(2)Condition A is that a company (“the second company”) pays a dividend to another company (“the first company”).

(3)Condition B is that there is a third company which is a 10% associate of, and pays a dividend to, the second company.

(4)Condition C is that there is a succession of companies consisting of—

(a)a third company which is a 10% associate of, and pays a dividend to, the second company, and

(b)a fourth company which is a 10% associate of, and pays a dividend to, the third company.

(5)Condition D is that there is a succession of companies consisting of—

(a)a third company which is a 10% associate of, and pays a dividend to, the second company, and

(b)two or more companies (the fourth and fifth companies, and so on) each of which is a 10% associate of, and pays a dividend to, the company above it in the succession.

(6)For the purposes of this section, a company (“X”) is a 10% associate of another company (“H”) if H—

(a)controls directly or indirectly, or

(b)is a subsidiary of a company which controls directly or indirectly,

at least 10% of the voting power in X or at least 10% of the ordinary share capital of X.

(7)For the purposes of subsection (6), a company (“S”) is a subsidiary of another company (“P”) if P controls, directly or indirectly, at least 50% of the voting power in S.