Commentary

D6.616 Capital treatment—connection

Corporate tax
Corporate tax | Commentary

D6.616 Capital treatment—connection

Corporate tax | Commentary

D6.616 Capital treatment—connection

A vendor is connected with a company if he1:

  1.  

    (a)     has control of the company (see A1.156). Broadly a person will control a company if he has the power to ensure that the affairs of the company are conducted in accordance with his wishes, whether by virtue of his shareholdings or voting or other powers in relation to the company;

  2.  

    (b)     owns (by himself or with his associates) or is entitled to acquire, immediately or in the future2, more than 30% of the company's issued ordinary share capital, its loan capital and issued share capital taken together,

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