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HMRC internal manual

Company Taxation Manual

Corporation Tax: small profits relief: substantial commercial interdependence: accident of circumstance is not substantial commercial interdependence

In determining ‘control’ for the purposes of CTA2010/S18, the attribution of rights held by associates is not intended to apply where there is an ‘accident of circumstance’ but rather on whether there is, in a real sense, interdependence between the parties .

Each case will depend on its specific circumstances but there is no substantial interdependence in situations where links between companies consist solely of an accident of circumstance as it would be disproportionate to see this as evidence of interdependence.