Taxes Consolidation Act 1997 section 9

Subsidiaries

Section 9 defines the different categories of subsidiary company for tax purposes and explains how to calculate ownership percentages when shares are held through chains of intermediate companies.

• A company is a 51%, 75%, 90% or wholly-owned subsidiary depending on whether another company owns more than 50%, at least 75%, at least 90% or exactly 100% of its ordinary share capital respectively.
• Ownership means beneficial ownership, and for 51% and 75% subsidiaries it can be direct or indirect, whereas for 90% and wholly-owned subsidiaries the shares must be held directly.
• When shares are held through a chain of companies, the first company's ownership percentage in the last company is calculated by multiplying together the ownership percentages at each link in the chain.
• Where a company owns shares in another company through multiple routes, the percentages from each route are added together to determine total ownership.