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HMRC internal manual

International Manual

Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Indirect interests

A person may hold an indirect interest in a controlled foreign company. ICTA88/S749B(5)-(7) provides that where a company (B) has an interest in another company (C) and another company (A), or two or more persons together, has an interest in company B, company A has the same interest in C as does company B. When two or more persons jointly have a beneficial interest in a company they are treated as having the same interest in equal shares.