Factors taken into account in determining substantial commercial interdependence

2.  In determining for the purposes of section 27 of the Corporation Tax Act 2010 (attribution to persons of rights and powers of their associates) whether a relationship between two companies amounts to “substantial commercial interdependence”, the following factors are to be taken into account—

(a) the degree to which the companies are financially interdependent,

(b) the degree to which the companies are economically interdependent, and

(c) the degree to which the companies are organisationally interdependent.