Skip to content
Solved
SearchBrowse
Sign in

Contents

Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading “Indirect participation” in management, control or capital of a person

  • Section 158 Indirect participation: defined by sections 159 to 161
  • Section 159 Indirect participation: potential direct participant
  • Section 160 Indirect participation: one of several major participants
  • Section 161 Indirect participation: involvement in financing arrangements
  • Section 162 Indirect participation: sections 148 , 175 and 219(2): further financing cases
  • Section 162A Agreements for common management
  • Section 162B Arrangements to avoid participation condition
  • Section 163 Meaning of “connected” in sections 159 and 161
  1. “Indirect participation” in management, control or capital of a person
  2. Agreements for common management

Section 162A | Agreements for common management

From legislation.gov.uk

(1)Where a person (“A”) and another person (“B”) are the subject of common management arrangements, each of A and B is to be treated, for the purposes of this Chapter, as having control of the other.

(2)Common management arrangements means arrangements that—

(a)result in the management of A and B by the same person or group of persons, and

(b)include a mechanism that it is reasonable to suppose is intended to secure that the economic interests of shareholders in A and B being aligned.

(3)In this section “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable.

PreviousNext
PrivacyTerms