Section 177 | Connected persons

(1)In this Chapter, a “connected person” means a person who an officer of Revenue and Customs reasonably suspects is or has been—

(a)contravening an anti-avoidance enactment,

(b)connected to a person who is or has been contravening an anti-avoidance enactment, or

(c)connected to arrangements by reference to which a person is or has been contravening an anti-avoidance enactment.

(2)For the purposes of subsection (1)(b), two persons (“A” and “B”) are connected if—

(a)A is a director, manager, secretary or other officer or employee of B,

(b)A is a member of, or partner in, B,

(c)A is a trustee, settlor, beneficiary or administrator of a trust in respect of which B is a trustee, settlor, beneficiary or administrator, or

(d)A is accustomed to acting in accordance with B’s directions or instructions.

(3)For the purposes of subsection (1)(c), a person is connected to arrangements if the person is—

(a)to any extent involved in making the arrangements available for implementation by another person,

(b)to any extent involved in the organisation or management of the arrangements, or

(c)directly or indirectly benefiting from the arrangements.