Opco has 2 Holdcos and the shares of each Holdco are owned by 2 different individuals (unrelated), 50-50% respectively. In this case, the 3 corporations are not association (ignoring de facto control)?
Not enough information. You didn’t state whether the two holdcos had equal shareholdings in Opco. Also de facto control can be a question.
Just updated my question. Thank you
You have to look at each and every possible scenario to determine, no one can do that for you with all your factual information. https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/it64r4-consolid/archived-corporations-association-control.html
Probably not associated, but if the 2 individuals are friends, such that they discuss their business decisions together, and possibly make decisions that benefit each other, they would be considered non-arms-length, which would make the whole group associated (unless they designate the Opco as a CCPC “third” corp with no business limit).
This is very complex, say a minor has a father and mother that are not married, so mother and father are not associated, but they are each related and associated with the minor