Land and Buildings Transaction Tax (Scotland) Act 2013 Schedule 10 paragraph 47

Chapter 6 of Part 5 of the Corporation Tax Act 2010

Paragraph 47 applies existing Corporation Tax rules about equity holders and profit/asset distribution to determine subsidiary status for LBTT group relief purposes.

• The rules in Chapter 6 of Part 5 of the Corporation Tax Act 2010 are imported into the LBTT group relief framework.
• These rules govern how equity holders are identified and how profits or assets available for distribution are calculated.
• They are used specifically to test the economic ownership conditions for 75% subsidiary status under paragraph 44(b) and (c) of Schedule 10.
• This ensures consistency between the LBTT group relief subsidiary tests and the equivalent Corporation Tax group relief provisions.

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