Corporation Tax Act 2009 section 100

Connected persons and property arrangements

Section 100 defines what "connected persons" and "property arrangements" mean for the purposes of the reverse premiums rules in sections 96 to 99.

• Two persons are treated as connected if they are connected at any point during the period when the property arrangements are entered into
• The connection does not need to exist throughout the entire period — it only needs to exist at some point during that period
• "Property arrangements" covers not just the property transaction itself but also any arrangements entered into in connection with it, whether before, at the same time, or afterwards
• This is a broader definition of connectedness than the standard one, because it looks across the whole timeline of the property arrangements rather than at a single moment