Section 18G — Corporation Tax Act 2010: Attribution to persons of rights and powers of their partners

Attribution to persons of rights and powers of their partners 18G 1 This section applies if—

a it is necessary to determine in accordance with section 18E(4) and (5) whether a company is an associated company of another company, and b the relationship between the two companies is not one of substantial commercial interdependence.

2 In the application of section 451 (meaning of “control”: rights to be attributed) for the purposes of the determination, any person to whom rights and duties fall to be attributed under subsections (4) and (5) of that section is to be treated, for the purposes of those subsections, as having no associates.

3 The Treasury may by regulations prescribe factors that are to be taken into account in determining whether a relationship between two companies amounts to substantial commercial interdependence for the purposes of this section.