CFM39170 - Loan relationships: tax avoidance: index-linked gilt-edged securities: the relevant group
The 바카라 사이트˜relevant group바카라 사이트™
As it is possible for two companies within the same group to undertake a relevant hedging scheme together (for example, company A holds the index-linked gilts and company B enters into a matching total return swap), CTA09/S400A applies to schemes that operate on a group basis as well as solo company schemes.
The 바카라 사이트˜relevant group바카라 사이트™ for the purposes of CTA09/S400A, is defined as company A and any other company which is both 바카라 사이트˜associated with바카라 사이트™ company A at any time in the accounting period and party to the same relevant hedging scheme.
바카라 사이트˜Associated with바카라 사이트™
CTA09/S400C sets out that a company is 바카라 사이트˜associated with바카라 사이트™ another company if any of the following 5 conditions are met:
Condition 1 - the 바카라 사이트˜consolidation condition바카라 사이트™
Company A and company B are associated with each other if the financial results of both companies are required to be consolidated into accounts prepared under section 399 of the Companies Act 2006 or, if they are not to be consolidated into such accounts, then this is due to the exemption at section 399(3).
Condition 2 - connected companies
Company A and company B are associated with each other if they are connected with each other as defined at CTA09/S466 (see CFM35110).
Condition 3 - major interest
Company A and company B are associated with each other if one of those companies has a 바카라 사이트˜major interest바카라 사이트™ in the other company. The meaning of 바카라 사이트˜major interest바카라 사이트™ is the same as that used for loan relationship purposes (see CFM35920).
Condition 4 - the 바카라 사이트˜consolidation condition바카라 사이트™ and a 바카라 사이트˜major interest바카라 사이트™
Company A and company B are associated with each other if company A and a third company meet the 바카라 사이트˜consolidation condition바카라 사이트™ (see condition 1 above) and that third company has a 바카라 사이트˜major interest바카라 사이트™ (see condition 3 above) in company B.
Condition 5 - a 바카라 사이트˜major interest바카라 사이트™ and connection
Company A and company B are associated with each other if company A and a third company are 바카라 사이트˜connected바카라 사이트™ (see condition 2 above) and that third company has a 바카라 사이트˜major interest바카라 사이트™ in company B (see condition 3 above).