Corporation Tax Act 2010 section 721

When things other than ordinary share capital may be taken into account: Chapters 2 to 5A

Section 721 allows interests other than ordinary share capital — such as voting power or special powers — to be used when determining whether a company has undergone a change in ownership for corporation tax purposes.

• Where persons hold extraordinary rights or powers under a document regulating a company, ordinary share capital may not be the right measure of ownership changes
• The section applies when using the standard ordinary share capital test would produce misleading results about who ultimately benefits from tax relief
• Alternative measures include all share capital, any particular class of share capital, voting power, or any other special power
• These alternative measures can be used for the purposes of Chapters 2, 2A, 2B, 2C, 2D, 2E, 3, 4, 5 and 5A of the Act