CTM60280 | 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.