Related Commentary  Related HMRC Manuals

976(1)  A company is a “related company”, for the purposes of this Chapter, if, at any time in the relevant period, it was a member–

(a)of the same group as the taxpayer company,

(b)of a consortium which at that time owned the taxpayer company, or

(c)of the same group as a company which at that time was a member of a consortium owning the taxpayer company.

976(2)  For the purposes of subsection (1)(a), two companies are members of the same group if–

(a)one is the 51% subsidiary of the other, or

(b)both are 51% subsidiaries of a third company.

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