Taxation (International and Other Provisions) Act 2010 section 473

Meaning of "a worldwide group", "ultimate parent" etc.

Section 473 defines what constitutes a "worldwide group" for the purposes of the corporate interest restriction rules, and establishes the key terms used to describe the entities within such a group.

• A worldwide group consists of a top-level "relevant entity" (the ultimate parent) together with any entities consolidated beneath it in group accounts.
• An entity qualifies as the ultimate parent if it is a relevant entity that either heads up a group defined under international accounting standards (IAS) or is not part of any such group at all.
• A worldwide group can be a "single-company worldwide group" (just the ultimate parent on its own) or a "multi-company worldwide group" (the ultimate parent plus one or more consolidated subsidiaries).
• The definition of "IAS group" follows the meaning of a group as given by international accounting standards, which determines whether entities are treated as consolidated subsidiaries.