Corporation Tax Act 2009 section 363

Companies connected for sections 361 to 362A

Section 363 defines when two companies are treated as "connected" for the purposes of the rules on undervalue acquisitions of creditor rights and debt releases between connected companies.

• Two companies are connected if one controls the other, or both are controlled by the same person
• Connection at any point during a period of account counts as connection for the whole period
• Common control by the Crown, government departments, foreign sovereign powers or international organisations does not create a connection
• This definition differs from the general loan relationships connected company test by applying to periods of account rather than accounting periods