Substantial interest defined as control via voting shares or profit entitlement, determining tax attribution and aggregation rules. The explanation defines substantial interest for tax purposes: for companies, beneficial ownership of shares carrying a threshold portion of voting power (excluding fixed dividend only shares), and for other concerns, an aggregated entitlement to a threshold portion of profits, with aggregation permitted with specified associated persons during the previous year.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Substantial interest defined as control via voting shares or profit entitlement, determining tax attribution and aggregation rules.
The explanation defines substantial interest for tax purposes: for companies, beneficial ownership of shares carrying a threshold portion of voting power (excluding fixed dividend only shares), and for other concerns, an aggregated entitlement to a threshold portion of profits, with aggregation permitted with specified associated persons during the previous year.
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