Section 554Z1 | Interpretation: persons linked with A ^F1

(1)In this Part references to any person linked with A are references to—

(a)any person who is or has been connected with A,

(b)a close company in which A or a person within any other paragraph of this subsection is or has been a participator,

(c)a company in which A or a person within any other paragraph of this subsection is or has been a participator and which would be a close company if it were a UK resident company, or

(d)a company which is a 51% subsidiary of a company within paragraph (b) or (c).

(2)In applying section 993 of ITA 2007 for the purposes of subsection (1), two people living together as if they were a married couple or civil partners are treated as if they were spouses or civil partners of each other.^F2

(3)In subsection (1) “participator”—

(a)in relation to a close company, means a person who is a participator in relation to the company for the purposes of section 455 of CTA 2010 (see sections 454 and 455(5) of that Act), and

(b)in relation to a company which would be a close company if it were a UK resident company, means a person who would be such a participator if the company were a close company.