Commercial interdependence and associated companies

I have the following situation...

 

Company M derives all of its income, in the form of management fees, from company H.

Company M, which is a management company, has 3 suppliers, companies S,T and U.

Companies S, T and U derive roughly 50% of their income from M and 50% directly from H.

 

The shareholders and directors of company M are the sole shareholders of companies S, T and U, the majority (possibly sole) shareholder of H and  A N Other who is the internal accountant of H, so 5 shareholders in M owing 20% each (no one person in control).

 

My question, as the external accountant of M, S, T and U, is which companies, if any, are associated for corporation tax purposes due to financial interdependence or anything else.

 

If it is relevant, company H is a full rate corporation tax payer irrespective of the existence of the other companies.

 

Please note I am only after answers regarding the CT and associated company rules. Please no comments about IR35 or disguised remuneration, thanks!

 

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Commercial interdependence...

Steve Kesby |
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