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HMRC internal manual

Business Leasing Manual

Sale of lessor companies and similar arrangements: partnerships: partnerships involving consortia: meaning of 'associated company of the relevant company' (FA06/Sch10/Para26)

The concept of the associated company of the relevant company is extended to encompass structures involving consortium relationships so that if a leasing business is carried on by a company in partnership that is owned by a consortium or a company that is a 75% subsidiary of a holding company owned by a consortium the connection rule will reach up through the consortium to encompass companies that are members of the consortium and companies that are associated with members of the consortium.

The rules are different depending on whether there is a change in the partner company’s interest in the business of the partnership, see BLM81060, or there is a change in the ownership of the consortium member that is a partner in the leasing business, see BLM81065.