Taxation (International and Other Provisions) Act 2010 section 474

Interpretation of section 473: "relevant entity"

Section 474 defines what counts as a "relevant entity" for the purposes of identifying worldwide groups and ultimate parents under the corporate interest restriction rules.

• A relevant entity is either a company or an entity whose shares or interests are listed on a recognised stock exchange and are sufficiently widely held.
• Shares or interests are "sufficiently widely held" if no single participator holds more than 10% by value of all shares or interests in the entity.
• The definition of "participator" follows the same meaning used in the close companies rules in section 454 of the Corporation Tax Act 2010.
• Certain governmental bodies are specifically excluded from being relevant entities, including the Crown, Ministers, government departments, Northern Ireland departments, and foreign sovereign powers.