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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
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Close companies: close investment holding companies: group service companies

CTA2010/S34 (2) (d), (e), (f) (formerly ICTA88/S13A (2)(d), (e), (f))

A company will not be a close investment-holding company (CIC) if throughout the accounting period it exists wholly or mainly for one or more of the following purposes:

  • The purpose of co-ordinating the administration of two or more qualifying companies.
  • The purpose of a trade or trades carried on on a commercial basis by one or more qualifying companies or by a company that has control of the relevant company. Broadly Section 34 (2)(f) excludes from being a CIC a company which can show that it exists for the purpose of trading companies in the same group.
  • The purpose of making, by one or more qualifying companies or by a company which has control of the relevant company, of investments as referred to at Section 34 (2)(b). The broad effect here is to exclude from being a CIC a company that exists for the purpose of property investment companies in the same group.