Yes, if they are affiliates. Where the same individuals own both companies in substantially the same proportions, the entities can qualify as affiliates, and no parent-subsidiary structure is required. The relationship still has to be documented, and both companies must be actively doing business throughout.
Common ownership is a relationship, but only if it is proved
The permitted relationships are parent, branch, subsidiary and affiliate, and the affiliate branch of that list is what carries a case like this one. Two operating companies owned by the same two shareholders in the same proportions are affiliated through common control, and that is a recognised structure rather than a workaround. The difficulty is evidentiary.
Adjudicators do not accept a statement that the same people own both; they want the share registers, the subscription or share purchase documents, any shareholders agreement, and confirmation that no later share issuance, option grant or transfer has changed the proportions. Where a spouse or a holding company appears on one register and not the other, the common ownership may no longer be substantially the same, and that needs to be examined rather than glossed over. Both entities must also be doing business, meaning the regular systematic provision of goods or services, not merely holding an agency agreement or a bank account.