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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Close companies: tests: control - overseas governments and local authorities

A company should not be treated as a close company if the only persons who can be taken to have control of that company are any of the following:

  • Overseas governments.
  • The Crown Agents for Overseas Governments and Administrations.
  • Local authorities or local authority associations exempt from tax under CTA2010/S984 (formerly ICTA88/S519) (see CTM40850 onwards).

Nor should a company be treated as a close company if the only persons who can be taken to have control of that company are any of the above together with:

  • a company or companies resident in the UK which are not close, or
  • an overseas company or companies which, if resident in the UK, would not be close.