17U.K.In section 301 of ITA 2007, after subsection (1) insert—
“(1A)For the purposes of this Chapter, a company (“company A”) which is a subsidiary of a company that is not the relevant company (“company B”) is a qualifying 90% subsidiary of the relevant company if—
(a)company A would be a qualifying 90% subsidiary of company B (if company B were the relevant company), and company B is a qualifying 100% subsidiary of the relevant company, or
(b)company A is a qualifying 100% subsidiary of company B, and company B is a qualifying 90% subsidiary of the relevant company.
(1B)For the purposes of subsection (1A), no account is to be taken of any control the relevant company may have of company A.
(1C)For those purposes, a company (“company X”) is a qualifying 100% subsidiary of another company (“company Y”) at any time when the conditions in subsection (1)(a) to (e) would be met if—
(a)company X were the subsidiary,
(b)company Y were the relevant company, and
(c)in subsection (1) for “at least 90%” in each place there were substituted “ ;100% ”.”