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Legislation
Corporation Tax Act 2009

Chapter 5 Connected companies relationships: introduction and general

  • Section 348 Introduction: meaning of “connected companies relationship”
  • Section 349 Application of amortised cost basis to connected companies relationships
  • Section 350 Companies beginning to be connected
  • Section 351 Companies ceasing to be connected
  • Section 352 Disregard of related transactions
  • Section 352A Exclusion of credits on reversal of disregarded loss
  • Section 352B Eliminating tax mismatch for loan relationships with qualifying link
  1. Chapter 5 · Connected companies relationships: introduction and general
  2. Introduction: meaning of “connected companies relationship”

Section 348 | Introduction: meaning of “connected companies relationship”

From legislation.gov.uk

(1)This Chapter contains some general rules relating to connected companies relationships.

(2)For the purposes of this Part a debtor relationship of a company is a connected companies relationship if there is a connection between—

(a)the company, and

(b)another company standing in the position of a creditor as respects the debt in question.

(3)For the purposes of subsection (2) a company is treated as standing in the position of a creditor if it indirectly stands in that position by reference to a series of loan relationships or relevant money debts.

(4)For the purposes of this Part a creditor relationship of a company is a connected companies relationship if there is a connection between—

(a)the company, and

(b)another company standing in the position of a debtor as respects the debt in question.

(5)For the purposes of subsection (4) a company is treated as standing in the position of a debtor if it indirectly stands in that position by reference to a series of loan relationships or relevant money debts.

(6)For the purposes of this Part, if a loan relationship is a connected companies relationship at any time in an accounting period, it is treated as being such a relationship for the period.

(7)In this section “relevant money debt” means a money debt which would be a loan relationship if a company directly stood in the position of creditor or debtor.

(8)Section 466 (companies connected for an accounting period) applies for the purposes of this section.

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