Corporation Tax Act 2010 section 1017

Section 1015: other interpretation

Section 1017 provides additional definitions and interpretive guidance for determining whether securities are "special securities" under section 1015, covering business-result-dependent returns, securities connected with shares, funded companies, and associated companies.

• A security's return is not treated as dependent on business results merely because the return decreases when results improve or increases when results deteriorate
• Securities are connected with a company's shares where holders must also hold, acquire or dispose of a proportionate shareholding, due to the nature of the rights or transfer conditions attached to those securities or shares
• A company is a "funded company" if arrangements exist for it to be put in funds, directly or indirectly, by the issuing company or a company associated with the issuing company
• A company is associated with the issuing company if one is a 75% subsidiary of the other, or both are 75% subsidiaries of a third company