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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.1 Groups of companies—scope and definition /Definition of a group / D2.106 Definition of a group—meaning of subsidiaries
Commentary

D2.106 Definition of a group—meaning of subsidiaries


Corporate tax

A company is a subsidiary if it1:

  1. Ìý

    •ÌýÌýÌýÌý is a body corporate (D2.107)

  2. Ìý

    •ÌýÌýÌýÌý has ordinary share capital (D2.108)

  3. Ìý

    •ÌýÌýÌýÌý is beneficially owned (D2.109) by another body corporate

Some guidance on the concept of beneficial ownership may be found in CG11730, CTM06030 and CTM36125, though not specifically in connection with the provisions described here.

A subsidiary can be either a 51%, 75% or 90% subsidiary. The extent of ownership required to form a group varies depending upon the provisions in

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