Revenue Precedents

A company had raised up to its limit in respect of its trade. The daughter of the family controlling the original company proposed to raise money for a complimentary trade. Were the companies associated for the purposes of this section? Yes. The companies were pursuing a common purpose and a group of persons with a reasonable commonality of identity had determined the trading operations to be carried on. 6576/95

An individual set up a number of companies and raised BES funds to the limit. His daughter set up a new venture to produce a completely different product. She was qualified in her own right. Were the companies associated for the purposes of this section? No, because there were no business or financial transactions between the companies, nor agreements, arrangements or understandings under which the person with the existing companies or an associated person would take over the venture at a future date. 6200/96

A manufacturer was having difficulty obtaining raw materials. The company organised a BES scheme for an entirely independent raw materials supplier. There were certain agreements between the companies including the sharing of manufacturing facilities and obligations in relation to the sale of outputs. The supplier raised BES funds up to the limit. A BES scheme was proposed for a second supplier controlled by entirely different parties. Were the companies associated for the purposes of this section? Yes. The company shared a common purpose with the first supplier. 6089/95