Q&As

Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449 of the CTA 2010 apply if the entity is offshore?

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Published on LexisPSL on 19/08/2015

The following Tax Q&A provides comprehensive and up to date legal information covering:

  • Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449 of the CTA 2010 apply if the entity is offshore?

Can an entity be a ‘connected [person]’ as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an ‘associated company’ with the meaning of CTA 2010, section 449 if the entity is offshore?

Both terms are applied in a number of places throughout the taxes acts, so the precise meaning will depend on, and must be considered in the context of, the specific rules being considered.

The concept of 'connected' is generally used in corporate tax legislation to charge tax on the market value of a transaction (rather than the actual consideration paid), to restrict losses and to avoid taxpayers taking advantage of timing mismatches.

However, both terms also hinge on the separate conc

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