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Official guidance
Company Taxation Manual

CTM60700 · Close companies: close investment holding companies

  • CTM60705 · Introduction
  • CTM60710 · Definition
  • CTM60720 · Purpose
  • CTM60730 · Wholly or mainly
  • CTM60740 · Lettings to connected persons
  • CTM60750 · 'qualifying company'
  • CTM60760 · Holding companies
  • CTM60770 · Group service companies
  • CTM60780 · Liquidation
  • CTM60790 · Restriction on payment of tax credit
  1. Close companies: close investment holding companies: contents
  2. Close companies: close investment holding companies: group service companies

CTM60770 | Close companies: close investment holding companies: group service companies

From HM Revenue & Customs · Company Taxation Manual

CTA2010/S18N (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 candidate company. Broadly Section 18N (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 candidate company, of investments as referred to at Section 18N (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.

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