Readers’ forum: What is a ‘group’?

For argument’s sake let’s imagine a group of 20 friends. None of these friends are personally connected with one another in any way. Jointly ten of the friends own all the shares in A Ltd and the other ten own all the shares in B Ltd. Are A Ltd and B Ltd connected per CTA 2010 s 1122(2)(d)?

To be clear I am very aware that the answer must be no. If the answer were to be yes every company would be connected to literally every other company. However CTA 2010 s 1122(2)(d) states:

‘(2) A company is connected with another company if –

(d) a group of two or more persons has control of both companies and the groups either consist of the same persons or could be so regarded if (in one or more cases) a member of...