188体育

Section 430 CTA 2010

When the partner company is a consortium company and there is a change of ownership of the consortium company the meaning of associated company extends to cover companies associated with the relevant consortium member.

Example: associated companies - consortia - change in ownership of partner:

In this example the partner鈥檚 interests in the partnership business remain constant. Instead C Ltd, a member of the consortium, sells part of its interest in the partner company, A Ltd, to F Ltd. A Ltd is a partner in the leasing business and a consortium company. The change is in the ownership of the consortium company.

Paragraph 26 (4) deals with situations where there is a change in the ownership of the consortium company but no qualifying change in the consortium company鈥檚 interest in the partnership business.

Attention focuses on the 鈥榬elevant member of the consortium鈥�.

The 鈥榬elevant member of the consortium鈥� is a company that is:

• a member of the consortium at the start of the day; when
• there is a qualifying change in ownership during the day; and
• the company would be 鈥榗ompany E鈥� in relation to the consortium company. These terms are defined in paragraph 12 see BLM80320 above

insert 鈥榓ttachment at BLM80165B鈥� here

In this example C Ltd is the relevant member of the consortium because it is:

• a member of the consortium and
• it is 鈥榗ompany E鈥� in relation to the consortium company and
• there is a qualifying change in ownership at this tier.

The associated companies are therefore C Ltd and the companies associated with C Ltd. These companies are shaded grey in the diagram.