
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.
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).
3 
The factors specified in paragraph 3(3) of Schedule 1 to the National Insurance Contributions Act 2014 (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