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Corporation Tax Act 2010

Section 1067: Companies acting in concert or under arrangements

3117.This section deals with the situation where two or more close companies act together to provide benefits to each other’s participators. It is based on section 418(7) of ICTA.

3118.In such a case the benefits are deemed to be provided by a close company to its own participator and hence treated as a distribution.

3119.Subsection (2) makes clear that this provision applies only for the purposes of the sections rewriting section 418 of ICTA.

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