Commentary

D1.1204A Related 51% group company

Corporate tax
Corporate tax | Commentary

D1.1204A Related 51% group company

Corporate tax | Commentary

D1.1204A Related 51% group company

For the latest New Development, see ND.1898.

The provisions in this article relating to corporation tax rates apply from 1 April 2015 to ring fence profits only. From this date for non-ring fence trades there is only one 'main rate' of corporation tax (see D1.1201). Where an accounting period straddles this date it is split into two notional periods. For the small profits rate that applied before 1 April 2015 (see D1.1205). This definition is also used to determine the limits that apply to a company's augmented profits in order to test whether it is a 'large' or 'very large' company for the purpose of the instalment payments regime (see D1.1329 and D1.1329A).

The anti-fragmentation rules for computing marginal relief (now applicable only to ring fence profits) have been simplified by replacing the associated companies rules with a 'related

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