Corporation Tax Act 2009 section 133J

Meaning of "customer"

Section 133J defines who counts as a "customer" for the purposes of the rules restricting tax deductions for compensation payments and the related disclosure condition.

• A person is a customer of a company if they use, have used, or even contemplated using a financial service provided by that company, or if they hold relevant rights or interests connected to such a service.
• A financial service means a service provided in carrying on regulated activities, communicating or approving investment-related invitations or inducements, or providing relevant ancillary services where the company is an investment firm or credit institution.
• A person has a relevant right or interest if their right derives from another person's use of the service, or if it could be adversely affected by someone acting on their behalf or in a fiduciary capacity using the service — covering situations such as intermediaries.
• Beneficiaries of a trust where the company acts as trustee are treated as customers, and anyone who deals with the company in the course of the company providing a service is also treated as using that service.