8(1)A “group other than an MNE group” means a group consisting of two or more relevant bodies—U.K.
(a)each of which is a member of the group by virtue of sub-paragraph (3) or (4),
(b)at least two of which are UK companies,
which is not an MNE Group.
(2)For the purposes of the condition in sub-paragraph (1)(b) a UK permanent establishment of a foreign member of a group is to be treated as if it were a UK company and a member of the group.
(3)A relevant body is a member of a group if—
(a)another relevant body is its 51% subsidiary, or
(b)it is a 51% subsidiary of another relevant body.
(4)Two relevant bodies are members of the same group if—
(a)one is a 51% subsidiary of the other, or
(b)both are 51% subsidiaries of another relevant body.
(5)Chapter 3 of Part 24 of CTA 2010 (meaning of 51% subsidiary) applies for the purposes of this Schedule as it applies for the purposes of the Corporation Tax Acts (but with the modification in sub-paragraph (6)).
(6)It applies as if references to a body corporate were references to a relevant body.