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is less than 25 per cent of such profits or assets (as the case may be) of the subsidiary company at such time, and sections 413, 414, 415 and 418 shall, with any necessary modifications but without regards to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets (as the case may be) to which a company is beneficially entitled as they apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets to which a company is so entitled.

“group relief” has the meaning assigned to it by section 411;

(3) For the purposes of paragraph (b)(ii)(II) of the definition of “non-resident person” paragraph (b)(iii)(I) of the definition of “qualifying non-resident person” in subsection (1), sections 412 to 418 shall apply as those sections would apply for the purposes of Chapter 5 of Part 12 if subparagraph (iii) of section 411(1)(c) were deleted.

(i) section 411(1)(c) were deleted, and

(5) For the purposes of subsection (3)(b)(ii)(II) subsection (3)(b)(iii)(I), sections 412 to 418 shall apply as those sections would apply for the purposes of Chapter 5 of Part 12 if subparagraph (iii) of section 411(1)(c) were deleted.

(i) if section 411(1)(c) were deleted, and

(c) For the purposes of paragraph (b)(i)(II), sections 412 to 418 shall apply as those sections would apply for the purposes of Chapter 5 of Part 12 if section 411(1)(c) were deleted.

(ii) by a company (in this paragraph referred to as the “first-mentioned company”) to which subparagraphs (i) and (ii) of subsection (5)(a) apply to another company resident in the State where that other company is deemed to be a member of the same group of companies as the first-mentioned company and for this purpose the provisions of subsection (1) of section 411 shall apply to determine whether companies are deemed to be members of the same group of companies as if references in that subsection to a 75 per cent subsidiary were references to a 51 per cent subsidiary,

“holding company” has the same meaning as in section 411;

“group relief” has the meaning assigned to it by section 411;

“foreign loss” means a loss or other amount eligible for group relief in accordance with section 411(2A);

“surrendering state” means the relevant Member State in which the surrendering company referred to in section 411(2A) is resident for the purposes of tax.

(7) For the purpose of giving effect to this section “accounting period”, in relation to a surrendering company, means a period which would be an accounting period of the company if the company became resident in the State, and accordingly within the charge to corporation tax, at the time when it became a 75 per cent subsidiary referred to in section 411(2A)(a)(ii).

(a) in an accounting period one of the 2 companies has trading losses or other amounts eligible for relief from corporation tax which apart from this section it would be entitled to surrender as mentioned in section 411(2), and

(a) in any accounting period the trading company had trading losses or other amounts eligible for relief from corporation tax which apart from this section it would be entitled to surrender as mentioned in section 411(2), and

then, for the purposes of this Chapter, the trading company shall be treated as though it were not (as the surrendering company) within paragraph (a), (b) or (c) of section 411(3).

(4) In a case within paragraph (a) of subsection (2), a notice under that subsection may be served on the surrendering company (within the meaning of section 411) instead of or as well as on the company claiming relief.

“75 per cent subsidiary”, in relation to a company, has the meaning assigned to it for the purposes of the Corporation Tax Acts by section 9, as applied for the purposes of section 411 by paragraphs (b) and (c) of subsection (1) of that section.

(c) Notwithstanding sections 411 and 616, the producer and the qualifying company shall be deemed not to be members of the same group of companies for the purposes of—

(i) section 411, or

(ii) In applying sections 413 and 415 in determining the percentage of share capital or other amount which a shareholder beneficially owns or is beneficially entitled to under subparagraph (i), no regard shall be had to the provisions of section 411(1)(c).

(B) sections 413 to 419 shall apply as they apply for the purposes of Chapter 5 of Part 12 but as if “in a relevant territory” were substituted for “in the State” in subparagraph (iii) of section 413(3)(a) and as if paragraph (c) of section 411(1), other than that paragraph as it applies by virtue of subparagraphs (i) and (ii) clauses (I) and (II) of subparagraph (i), were disregarded,

(1) In this section, “claimant company” and “surrendering company” have the meanings respectively assigned to them by section 411.

(II) paragraph (c) of section 411(1) were deleted;

(a) both the predecessor and successor were, at the time of the event, members of the same group of companies within the meaning of section 411(1), and

(ii) paragraph (c) of section 411(1) were deleted;

at such time before the disposal, and sections 413 to 415 and section 418 shall apply, but without regard to section 411(1)(c) in so far as it relates to those sections, with any necessary modifications, to the determination for the purposes of this paragraph of the percentage of share capital or other amount which a shareholder beneficially owns or is beneficially entitled to, as they apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such amount which a company so owns or is so entitled to.

(2) Where relief in respect of interest paid, being interest treated as a charge on income, is claimed by virtue of section 420(6), any question under this section as to what benefit might be expected to accrue from the transaction under which that interest is paid shall be determined by reference to the claimant company (within the meaning of section 411(2)) and the surrendering company (within the meaning of that section) taken together.

(ii)sections 412 to 418 shall apply for the purposes of this paragraph as they would apply for the purposes of Chapter 5 of Part 12 if section 411(1)(c) were deleted,

(7) For the purposes of this section, 2 companies are members of the same group if and only if they would be such members for the purposes of section 411.