Corporation Tax Act 2010 (c. 4)

Part 23 U.K. Company distributions

Chapter 4 U.K. Special rules for distributions made by certain companies

Close companies U.K.

1067 Companies acting in concert or under arrangements U.K.

(1) Subsection (2) applies if—

(a) each of two or more close companies makes a payment,

(b) each of those payments is made to a person who—

(i) is not a participator in the company making the payment, but

(ii) is a participator in another of those companies, and

(c) the companies are acting in concert or under arrangements made by any person.

(2) For the purposes of sections 1064 to 1066, each payment made to a person as mentioned in subsection (1) is treated as if it had been made to that person by the company in which that person is a participator.

(3) Subsections (1) and (2) apply, with any necessary adaptations, in relation to the giving of any consideration, and to the provision of any facilities, as they apply in relation to the making of a payment.