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Who is associated with whom, and why? NICHOLA ROSS-MARTIN investigates
KEY POINTS
- The effect of associated companies on corporation tax liabilities.
- ESC C9 was legislated into CTA 2010 s 27.
- The definition of control in CTA 2010 s 450.
- Applying the minimum controlling combination rules in a practical example.
- Don’t forget to determine whether there is substantial commercial interdependence.
If ever there was a topic ripe for simplification it is the associated company rules. When one company is associated with another for corporation tax purposes CTA 2010 s 24 tells us to reduce the lower and upper limits for corporation tax accordingly.
This means associated companies may pay higher rates of tax than singleton companies. The reason for this rule is to prevent the splitting of a business between companies in order to avoid the marginal or...
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