The percentage shareholdings shown in this diagram assume that ICTA88/S410 (arrangements) and ICTA88/S413 (7) (entitlement to profits and assets tests) do not apply.
L and X are consortium members ( CTM80530). L is also a link company ( CTM80550).
If CH’s business is wholly or mainly the holding of shares or securities in 90% trading subsidiaries it is a directly owned holding company, which is a company owned by the consortium (CTM80530).
If CT1, CT2 and CT3’s busines is wholly or mainly in carrying on a trade, they too are companies owned by the consortium. CH, CT1, CT2 and CT3 are also consortium companies for the purposes of ICTA88/S406 ( CTM80550). They are also group/consortium companies for the purpose of ICTA88/S405 ( CTM80580). Claims and surrenders of group relief between them are group claims for the purposes of ICTA88/S405.
P, S1, and S2 are group members for the purposes of ICTA88/S406 (CTM80550). Claims and surrenders of group relief between them are not group claims for the purposes of Section 405.
L’s relevant fraction ( CTM80540) of any amount surrenderable by CH is 60%, X’s is 40%.
