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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Debt cap: failure to make statements of allocation: worldwide group with more than one ultimate UK parent

What happens if there is more than one ultimate UK parent

It is possible that a worldwide group may have more than one ultimate UK parent for the debt cap rules. For example, an overseas parent company may have two UK holding companies, each with a number of UK subsidiaries. In this case each ultimate UK parent is responsible for providing the information required by the group companies for which it is the only ultimate UK parent.

If, however, a company falls within the UK group of more than one ultimate UK parent (thus, in the example above, a company might be 60% owned by one UK holding company and 40% owned by the other), then each ultimate UK parent is responsible for meeting the obligations of the ultimate UK parent set out in the Regulations and TIOPA10/PT7.