Related Commentary  

199(1)  Conditions A to E are the pre-conditions for the purposes of section 200.

199(2)  Condition A is that both of the affected persons are companies.

199(3)  Condition B is that only one of the affected persons (“the advantaged person”) is a person on whom a potential advantage in relation to United Kingdom taxation is conferred by the actual provision.

199(4)  Condition C is that the other affected person (“the disadvantaged person”) is within the charge to income tax or corporation tax in respect of profits arising from the relevant activities (see section 216).

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