Capital Allowances Act 2001 section 212I

Relevant percentage share

Section 212I defines how to calculate a company's "relevant percentage share" in the profits or losses of an activity, for the purposes of the anti-avoidance rules on allowance buying.

• A company's "relevant percentage share" is its percentage share in the profits or losses of the relevant activity.
• This percentage share must be determined on a just and reasonable basis.
• The determination must have particular regard to the factors that would normally be used to allocate a firm's profits or losses between partners under corporation tax rules.
• However, the special rules that reallocate profits where some partners have losses (and vice versa) are to be disregarded when making this determination.