UK Tax Questions? Ask a UK Tax Advisor for answers ASAP
Looks like you are offline
However please say why you think that the company would be ignored for Associated company purposes
Quite clearly the holding company is doing more than MERELY receiving dividends from the subsidiary and distributing them BUT will be actively carrying out a trading/business function - again clearly within the ambit of UK corporation tax if UK resident
So I am sorry to disappoint you but the Holding Company will quite clearly be an Associate of its subsidiary and vice versa
I hope that this helps you and basically UNLESS a company is not carrying on a business - whether UK resident or not - and is merely receiving and distributing dividends from the subsidiary it is going to be reckonable as an associated company. Of course if they are a group the potential damage of the associated company rules might be mitigated by group relief if both are UK liable to CT companies.
I hope that you are satisfied with the answer and that you will be able to rate the JA service as good or better but if there are any doubts please do not hesitate to come back to me as the question has now been converted to Q&A
Thank you for your advice, it is as I expected but thought perhaps I was missing something.
Usual story of client meeting Joe Bloggs in the pub and coming back with
sparse information, as you suggest may be a group situation.