Taxation (International and Other Provisions) Act 2010 section 476

Continuity of identity of a worldwide group through time

Section 476 sets out how to determine whether a worldwide group at one point in time is the same worldwide group as at an earlier point in time, even though the entities within the group may have changed.

• The section addresses the question of whether a worldwide group retains its identity as the same group over a period of time.
• The test for continuity is based solely on who the ultimate parent entity of the group is.
• A worldwide group at a later date is the same group as at an earlier date if and only if the same entity is the ultimate parent at both points in time.
• That entity must also have been the ultimate parent of a worldwide group continuously throughout the entire period between those two points in time.