Part 22Miscellaneous provisions

Chapter 7Recovery of unpaid corporation tax due from non-UK resident company

976Meaning of “related company”

(1)

A company is a “related company”, for the purposes of this Chapter, if, at any time in the relevant period, it was a member—

(a)

of the same group as the taxpayer company,

(b)

of a consortium which at that time owned the taxpayer company, or

(c)

of the same group as a company which at that time was a member of a consortium owning the taxpayer company.

(2)

For the purposes of subsection (1)(a), two companies are members of the same group if—

(a)

one is the 51% subsidiary of the other, or

(b)

both are 51% subsidiaries of a third company.

(3)

For the purposes of subsection (1)(c), two companies are members of the same group if they are members of the same group of companies within the meaning of Part 5 (group relief).

(4)

For the purposes of this Chapter—

(a)

a company is a member of a consortium if it is a member of a consortium within the meaning of Part 5, and

(b)

a company is owned by a consortium if it is owned by a consortium within the meaning of that Part.