CTM81000 onwards) has effect for the
purposes of (c) and (d) of
CTM81240. However, when you apply this
guidance for the purposes of ICTA88/S240, you should bear in mind
the contents below.
Interpret any reference to 'relevant accounting period' as meaning either:
The parent company has to establish that it is entitled to more than 50%:
Note that the principal/subsidiary relationship may exist
between two companies for the purposes of surrendering ACT but not
for the purposes of group relief. This is because the test for the
surrender of ACT is by reference to a 51% relationship, rather than
the 75% relationship, which is the test for the purposes of group
Where in CTM81000 onwards it is stated that a payment to an equity holder (for example, an interest payment) is to be treated as a distribution to the equity holder, such treatment applies only for the purposes of ICTA88/S240. The question whether the payment is a distribution for the purposes of ICTA88/S209 must be determined in accordance with the provisions applying to Section 209.