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HMRC internal manual

Company Taxation Manual

Corporation Tax: small profits relief: associated company - definition

A company is an ‘associated company’ of another company if one of the two has control of the other, or both are under the control of the same person or persons (CTA10/S25 (4), formerly ICTA88/S13 (4)). ‘Control’ for this purpose is defined as for close companies (CTA10/PART10 S450 and S451- formerly ICTA88/S416 (2) to (6), see CTM60210).

A company may be an ‘associated company’ no matter where it is resident for tax purposes.