CTM21530 - ACT: FID: international headquarters companies (IHC): foreign held

ICTA88/S246S (10)

For the purposes of the tests in CTM21510, a company was a foreign held company in an accounting period if throughout the accounting period:

• at least 80% of the company’s share capital was owned by persons who were not UK resident at any time in the accounting period,

or

• the company was wholly owned by another company, and at least 80% of that other company’s share capital was owned by persons who were not UK resident at any time in the accounting period.