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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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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.