Mrs A and Mr A recently got married
Mrs A owns 100% shareholdings in Co.A
Mr A owns 75% shareholdings in Co.B
Mr.B (Mrs.A Brother) owns 95% shareholdings in Co.C
There is no substantial commercial interdependence
Is my understanding correct that because of the changes to s.27 of the Corporation Tax Act the companies will no longer be counted as associated companies for the purposes of the CTA
Replies (1)
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You are correct
There is no common control and no substantial commercial dependence, they are not associated companies.