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CT 600 and Associated companies
Comments
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I think what is required is for someone to interpret this correctly and it's not always just the accountant that can do this. In my post above if it was simple as 1. and 2. of section 18E then why would they further go to make an exception under SCI. The problem with HMRC is that the rules and explanations are written by people that don't necessarily have writing skills.
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If you want someone other than HMRC, or us on MSE, to define associated companies try here;
Associated companies: At a glance - www.rossmartin.co.uk"A company is an associated company of another at any time when:One of the two has control of the other, orBoth are under the control of the same person or persons.
Control is determined according to any of the following tests:Percentage share ownership.Voting power.Any rights.Entitlement to assets on winding up (loan creditors)."
or;
What does it mean to be an associated company? - PKF Littlejohn (pkf-l.com)
"The key metric for determining whether a company is associated with another is ‘control’. In its simplest form, one company is associated with another if one company controls the other, or both companies are controlled by the same person(s) either now or in the future. There is a ‘test’ of control which is defined by voting power, ordinary share capital, distributable profits and rights on a winding up. Person(s) can be a company, an individual(s), trustees of a trust, or partners in a partnership."
Not sure what else you're looking for.
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I have no skin in the game-and not forcing anyone to reply to this thread. I merely pick a topics where I have seen points of argument put forward by various businesses and colleagues. Maybe HMRC could just say where the same people/sharholders run multiple companies then they will all be treated as being associated and then the other scenerio is when 1 company has control over another.0
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