Corporation Tax Act 2010 section 1154

Meaning of "51% subsidiary", "75% subsidiary" and "90% subsidiary"

Section 1154 defines the three levels of subsidiary relationship — 51%, 75%, and 90% — based on beneficial ownership of ordinary share capital, and explains the role of direct and indirect ownership in meeting each threshold.

• A company is a 51% subsidiary if more than 50% of its ordinary share capital is beneficially owned directly or indirectly by another company.
• A company is a 75% subsidiary if at least 75% of its ordinary share capital is beneficially owned directly or indirectly by another company.
• A company is a 90% subsidiary if at least 90% of its ordinary share capital is beneficially owned directly — not indirectly — by another company.
• All references to ownership in this context mean beneficial ownership, not merely legal or nominee ownership.