Chapter CTM03805

Published date16 April 2016
Record NumberCTM03805
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

A loan creditor may have control of a company under CTA10/S450 (3)(d) but CTA10/S29 (formerly ESCC9) may nevertheless prevent two companies from being regarded as associated where:

  • there is common control of two companies by a single loan creditor, or
  • a loan creditor company has control of another company.

This will be so where control or common control arises only by under CTA10/S450 (3)(d) or its predecessor and, the loan creditor is either:

  • not a close company, or
  • the...

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