HMRC internal manual

Company Taxation Manual

CTM03710 - Corporation Tax: small profits relief: associated companies - detailed provisions - introduction

For the purposes of CTA10/S25 (4), a company is an associated company of another at a given time if at that time:

  • one of the companies has control of the other, or
  • both of the companies are under the control of the same person or persons (CTM03730).

Control for this purpose is construed in accordance with the close company provisions in CTA10/PART10 (sections 450 and 451), formerly ICTA88/S416. See CTM60210 to CTM60230 for the meaning of control and CTM03790 to CTM03830 for the treatment of companies controlled by certain loan creditors, through holding fixed rate preference shares, or by trustees.