Old rules: loan relationships: connected persons: connection through control
Connection through control
This guidance applies only to accounting periods starting before 1 January 2005
Companies were connected under FA96/S87(3) where at any time in an accounting period
- one party to the loan relationship controlled the other, or
- the two parties were under common control.
There was an exception: FA96/S87(4) stated that companies were not connected if they were under the common control of
- the Crown
- a Minister of the Crown
- a government department
- a Northern Ireland department
- a foreign sovereign power
- an international organisation (defined at FA96/S103 as one to which two or more sovereign powers, or their governments, belong), or
- Scottish Ministers (S117 Scotland Act 1998).
These rules are now at CTA09/S466 and are essentially unchanged (CFM35110).