Corporation Tax Act 2009 section 466

Companies connected for an accounting period

Section 466 defines when two companies are treated as "connected" for the purposes of the loan relationships rules in a given accounting period.

  • Two companies are connected for an accounting period if, at any time during that period, one controls the other or both are controlled by the same person
  • Companies are not treated as connected merely because they are both under the control of the Crown, a government minister or department, a foreign sovereign power, or an international organisation
  • The connection may be disregarded in certain circumstances, and special rules apply where companies are partners in the same partnership and one is treated as controlling the other
  • The meaning of "control" for these purposes is given its own specific definition, and this connected company test applies only where other provisions of Part 5 specifically invoke it

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