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6.6.1. Distributions from Controlled Companies

Where the recipient controls the payer (CTA 2009, s. 931E(2)) or where the recipient is one of two persons who together control the payer which has at least 40 per cent of the holdings, rights and powers by means of which the pair exercise control, and the other person has at least 40 per cent, but no more than 55 per cent, of the holdings, rights and powers by means of which the pair exercise control (CTA 2009, s. 931E(3)).