Corporation Tax Act 2009 section 1178

Persons having a "relevant connection" to a company

Section 1178 defines when a person is considered to have a "relevant connection" to a company for the purposes of the land remediation relief rules, which can affect whether the company qualifies for tax relief on remediation expenditure.

  • A person has a relevant connection to a company where the company's land is contaminated or derelict wholly or partly because of something the person did or failed to do
  • The connection exists if the person was connected to the company at the time the contaminating act or omission occurred
  • The connection also exists if the person was connected to the company when the company acquired a major interest in the land
  • The connection further exists if the person was connected to the company at any time when relevant land remediation work was being carried out by or on behalf of the company

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