.png)
.png)
Two companies have recently entered into a transaction the tax treatment of which would depend on whether they are connected with each other for tax purposes.
Burrow Limited is a UK company whose 100 ordinary shares are equally owned by James and his wife Lily. Willow Limited is also a UK company whose 100 ordinary shares are equally owned by Fred and George – the adult sons of James and Lily.
We referred to the four tests under which a company would be connected to another company as set out in CTA 2010 s 1122(2) but could not reach a clear conclusion.
Our understanding of the criteria is that s 1122(2)(a) and s 1122(2)(d) are not met due to neither company being under the control of ‘the same person’ or the same ‘group of two or more persons’.
It is less clear whether...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
