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Chapter INTM255940

Document Cited authorities 1 Cited in Related
Vincent
Published date09 April 2016
Record NumberINTM255940
ICTA88/S752B

Where the interest by ordinary shares in the controlled foreign company is held indirectly, the interest of each higher company in a chain is computed on the basis of the percentage of total ordinary shareholding that each company holds in the company that is linked by ordinary shares to the controlled foreign company. Where the relevant interest is not held wholly via the same intermediate company each shareholding percentage will need to be computed separately and amalgamated.

The formula that produces the appropriate percentage of the relevant interest is:

P x S

P is a product of fractional interests. The first fractional interest is the fractional interest the relevant interest holds directly in the shares of a share-linked company. A share-linked company is a company which is linked by shares (directly or indirectly) to the controlled foreign company. The second fractional...

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