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Appendix B — practical examples

Published 9 February 2026

Group structure chart — example 1

The group structure chart shows the typical information customers should share with HMRC. A reference key and any supplementary information would accompany the diagram.

Explanation of the group structure chart (accessible version)

Company A (UK) is the top-level parent entity in the structure. It is a company represented by a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (UK).

It owns two entities directly, and is joined to these with a solid line:

  • Company B (US) (100% ownership)
  • Company C (UK) (100% ownership)

Company B (US) is owned directly by Company A (UK). Company B is represented by a rectangle with the company name in the centre. A small rectangle in the bottom right hand corner indicates the country of incorporation and tax residence (US).

It has ownership interests, which are show by a solid line, in:

  • Company Hybrid D (US) (100% ownership) 
  • Partnership E (UK) (20% ownership) 

Company C (UK) is owned directly by Company A (UK). Company C is represented by a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (UK).

It has ownership interests, shown by a solid line in:

  • Partnership E (UK) (80% ownership)
  • Company C AU branch (100% ownership)

Company Hybrid D (US) is owned directly by Company B (US) (100% ownership). Company Hybrid D is represented by an oval inside of a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (US).

Partnership E (UK) is jointly owned by Company B (US) (20% ownership) and Company C (UK) (80% ownership). Partnership E is represented by a triangle with the partnership name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (UK).

Company C AU branch is a branch of Company C (UK). It is represented by an oval with the branch name in the centre. A small rectangle in the bottom right corner indicates the country of establishment and tax residence (AU).

Transaction flow diagram — example 2

The transaction flow diagram explains a transaction between connected companies. It is best practice to include enough detail to clearly explain the:

  • entity type
  • name
  • ownership or control
  • country of jurisdiction
  • special characteristics

Depending on your situation you should aim to show the flow of loans, cash or assets involved in the transaction. A reference key and supplementary information should accompany the diagram.

Explanation of the transaction flow diagram (accessible version)

Company G (UK) is the top-level parent entity in the structure. It is a company represented by a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (UK).

It owns directly 100% of Company H (JE). This is shown by a solid line. 

Company H (JE) is represented by an oval inside a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (JE).

It owns directly 100% of Company I (CH). This is shown by a solid line. 

Company I (CH) is a company represented by a rectangle with the company name in the centre. A small rectangle in the bottom right corner indicates the country of incorporation and tax residence (CH).

There are four arrows indicating financial flows:

  • a downward arrow from Company G to Company H, labelled Loan £5,000,000
  • an upward arrow from Company H to Company G, labelled Interest 5%
  • a downward arrow from Company H to Company I, labelled Equity £5,000,000
  • an upward arrow from Company I to Company H, labelled Dividend £250,000

This shows that Company G has made a £5 million loan to Company H. Company H has invested £5 million in return for equity in Company I. The return on the loan is 5%. The return on the equity is a dividend of £250,000.