KEY POINTS
- Legislation replaced ESC C9.
- Defining ‘interdependence’.
- Companies run for mutual benefit.
- Historical links may not be relevant.
- Some associated companies can be ignored.
Practitioners will undoubtedly be aware that the rules surrounding what is and what is not an associated company are changing.
As a result of the replacement of extra-statutory concession (ESC) C9 with new legislation HMRC are predicting that there will be winners from the new rules although there may be circumstances where there will also be losers.
This article concentrates on the main practical elements of the new rules.
However before getting caught...
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