Statutory Instruments
2022 No. 1203
Corporation Tax
The Corporation Tax Act 2010 (Factors Determining Substantial Commercial Interdependence) Regulations 2022
Made
17th November 2022
Laid before the House of Commons
21st November 2022
Coming into force
1st April 2023
The Treasury makes the following Regulations in exercise of the power conferred by section 18G(3) of the Corporation Tax Act 2010( 1 ).
Citation and commencement
1. These Regulations may be cited as the Corporation Tax Act 2010 (Factors Determining Substantial Commercial Interdependence) Regulations 2022 and come into force on 1st April 2023.
Application
2. These Regulations apply for the purpose of determining whether a relationship between two companies amounts to substantial commercial interdependence for the purposes of section 18G of the Corporation Tax Act 2010 (attribution to persons of rights and powers of their partners).
Factors to be taken into account in determining substantial commercial interdependence
3. The factors specified in paragraph 3(3) of Schedule 1 to the National Insurance Contributions Act 2014( 2 ) (companies whose relationship is not one of substantial commercial interdependence) are to be taken into account for the purposes of making the determination referred to in regulation 2.
Nigel Huddleston
Amanda Solloway
Two of the Lords Commissioners of Her Majesty’s Treasury
17th November 2022
2010 c. 4 . Section 18G was inserted by paragraph 3 of Schedule 1 to the Finance Act 2021 c. 26 .