Taxation (International and Other Provisions) Act 2010 section 404

Meaning of "investor", "related party investor" and investor's "share"

Section 404 defines three key terms — "investor", "related party investor" and an investor's "share" — used throughout the corporate interest restriction rules.

• An "investor" is any entity that holds an interest in the ultimate parent of a worldwide group, entitling it to a proportion of the group's profits or losses.
• A "related party investor" is an investor that is a related party of the ultimate parent throughout the entire period of account in question.
• An investor's "share" is the percentage of the group's profits or losses for a period to which the investor is entitled through its interest in the ultimate parent.
• These definitions apply across the whole of the corporate interest restriction provisions in this Part of the Act.