Corporation Tax Act 2010 section 1112

Arrangements between companies

Section 1112 deals with situations where two or more companies enter into arrangements to make distributions to each other's members, allowing the actions of one company to be attributed to another for distribution purposes.

• The section applies when two or more companies arrange to make distributions to each other's members.
• Actions taken by any one company in the arrangement can be treated as if they were carried out by any of the other companies involved.
• This attribution applies for the purposes of the company distributions rules in Part 23 of the Act.
• Certain provisions are excluded, namely those covering building society payments, agricultural or fishing co-operatives, close company expenses treated as distributions, and companies not carrying on a business.