In his splendid piece, Andy Poole highlights the risk that the 'associated company' provisions might apply to unconnected companies owned by partners in the same firm (see [2007] Gazette, 28 June, 10). This could have the effect of increasing the amount of corporation tax payable by those companies.


We have been working on this for some time with HM Revenue & Customs. We are advised that, while the Revenue continues to look at this issue, it has decided to temporarily stop working current open cases and not to take up any new cases for the time being.



However, enquiries in cases where there is evidence of a tangible business connection between companies and/or the fragmentation of business activities will continue. This, of course, is most unlikely to affect solicitors' partnerships.



George Bull, Baker Tilly, London