Where a corporate entity or relevant non-corporate entity is stapled to another entity, the two entities are treated for the purposes of the debt cap rules as if they were one single corporate entity or relevant non-corporate entity. The consolidated accounts will include the combined activities and subsidiaries of these companies and unit trusts and the group operates as a single economic enterprise.Īs the entities whose interests are ‘stapled’ together form, as a matter of economic and commercial reality, a single enterprise, TIOPA10/S342 treats them as part of a single worldwide group. The shareholders of each company and unit trust are therefore the same but in order to separate trading and investment activity, the shares of some group subsidiaries are held by the corporate entity while others are held by the unit trust. Investors have to buy a stapled security in the group, which will comprise a share in one or more companies and possibly also units in one or more unit trusts. These are a combination of securities that trade together as one security on a stock exchange. ‘Stapled’ entities at top of groupĪ number of groups have what are known as stapled securities at the top of their group structure. This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
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