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HMRC internal manual

Company Taxation Manual

Particular bodies: industrial and provident societies: second and third tier associations


Where a number of co-operative associations (CTM40590)co-operate in forming a joint association (referred to as a ‘second tier’ association or afederal’) for greater economy in marketing etc, it has been agreed that by concession onemay look through to the ultimate members of the constituent associations. Provided thatthose members satisfy the test of ICTA88/S486 (9) the ‘second-tier’ association may begranted the same treatment as its member associations.

This concession is published as ESCC13 and will also apply to ‘third tier’associations.