[The appeal against this decision is reported at [2004] BTC 279.]

Dr AN Brice, John Walters QC.

Decision released 21 July 2003.

Corporation tax – Preliminary issue – Small companies’ relief – Whether three companies associated – Whether all under control of same person – Income and Corporation Taxes Act 1988, s. 13, 416.


The special commissioners decided, as a preliminary issue, that three family companies were associated for purposes of the small companies' rate of corporation tax under s. 13 of the Income and Corporation Taxes Act 1988.


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