Section 43A

Two or more UK bodies corporate are eligible to be treated as members of a group if ...— one of them controls each of the others, one person (whether a body corporate or an individual) controls all of them, or two or more individuals carrying on a business in partnership control all of them. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . An individual carrying on a business and one or more UK bodies corporate are eligible to be treated as members of a group if the individual— controls the UK body corporate or all of the UK bodies corporate, and is established, or has a fixed establishment, in the United Kingdom in relation to the business. Two or more relevant persons carrying on a business in partnership (“the partnership”) and one or more UK bodies corporate are eligible to be treated as members of a group if the partnership— controls the UK body corporate or all of the UK bodies corporate, and is established, or has a fixed establishment, in the United Kingdom in relation to the business. In this section— “UK body corporate” means a body corporate which is established or has a fixed establishment in the United Kingdom; “relevant person” means an individual, a body corporate or a Scottish partnership. Section 43AZA contains provision for determining for the purposes of this section whether a body corporate, individual or partnership controls a UK body corporate.

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Source: legislation.gov.uk · retrieved 2026-07-28