Corporation Tax Act 2010 section 180

Company A's proportion if non-UK resident involved

Section 180 provides a special rule for calculating a parent company's ownership proportion in a subsidiary when a non-UK resident company is involved in the group structure, potentially reducing the proportion used for group relief purposes.

• Where a non-UK resident company is involved, Company A's ownership proportion must be recalculated using special assumptions set out in section 181
• In straightforward cases (no limited rights, temporary rights or option arrangements), the section 181 "alternative proportion" replaces the normal proportion if it produces a lower figure
• In more complex cases involving limited rights, temporary rights or option arrangements, each relevant calculation must be redone using the section 181 assumptions, and the lower result is used in each case
• The effect is always to cap the ownership proportion at the level produced by the section 181 assumptions, ensuring the non-UK resident element does not inflate the proportion available for group relief