»Ê¹ÚÌåÓýapp

Example 1

Company L is a banking company which agrees to pay compensation to a corporate customer (Company M). »Ê¹ÚÌåÓýapp compensation relates to a single transaction entered into between Company L and Company M. A disclosure in a relevant document indicates that Company M and one or more shareholders of Company M may be entitled to make a claim against Company L.

»Ê¹ÚÌåÓýapp shareholders are customers of company L, but use services which are unrelated to the transaction which has given rise to the compensation. »Ê¹ÚÌåÓýappir only interest in the compensation derives from their shareholding in Company M.

HM Revenue and Customs would not consider the shareholders to be “customers�, in respect of this transaction, for the purposes of CTA09/S133C(2), and would accept that the compensation is to, or for the benefit of, one (and only one) customer. This disclosure would not meet the disclosure condition.

Example 2

Company N is a banking company which has entered into transactions with companies O and its 100% subsidiary P. »Ê¹ÚÌåÓýapp transactions both relate to the same type of service provided by N. It is found that N has made an error in the service it has provided, and as a result N discloses in a relevant document that both O and P may be entitled to make a claim against company N.

Here, although O may have an interest in the compensation paid to P, and may ultimately have a claim to compensation in respect of P’s loss, O also has compensation deriving from its own customer relationship with N in respect of the same error. HM Revenue and Customs would not accept that CTA09/S133C(2)would disregard this disclosure.