[2004] EWHC 640 (Ch).

Chancery Division.

Lightman J.

Judgment delivered 30 March 2004.

Corporation tax – Small companies’ rate – Settlors established trust in favour of children – Shares in wholly owned subsidiary of company controlled by settlor held by trust – Trust also held majority of issued share capital in third company – Assessments raised on basis that taxpayer companies associated – Whether three companies associated for purposes of small companies’ rate – Income and Corporation Taxes Act 1988, s. 13, 416.

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