Corporation Tax Act 2010 section 153

Companies owned by consortiums and members of consortiums

Section 153 defines when a company is considered to be "owned by a consortium" and identifies who the members of that consortium are, including an extension to trading subsidiaries of consortium-owned holding companies.

• A company is owned by a consortium if it is not a 75% subsidiary of any company and at least 75% of its ordinary share capital is beneficially owned by other companies, each owning at least 5% of that capital.
• The companies each owning at least 5% of the share capital are treated as the members of the consortium.
• Where a holding company is owned by a consortium, a trading company that is a 90% subsidiary of that holding company (and not a 75% subsidiary of any other company) is also treated as owned by the consortium.
• This extension to trading subsidiaries complements the rules in section 133, which extend consortium relief to companies in the same group as a consortium member.