Common control

[russ23]

Company A is owned as folllows - 40%, Y - 40% and Z - 20% and company B as follows Y - 50% and Z - 50%.

As Y &Z have 60% of A and 100% of B I assume they are associated for tax purposes - does any one else agree?

Thanks in advance.

[AvocadoK]

I agree. Y&Z forms an irreducible group.

It would be different If Y held 51% of B. Y would then control B by himself, so A and B would not be under common control, always assuming Y and Z are not associated with each other. If it is important for Y and Z to be 50:50 in terms of share capital and votes, you could engineer "control" by Y for these purposes by arranging for Y to lend Company B £100, so that Y has more than 50% of assets on a winding up.
AK

[russ23]

Thanks AK