Corporation Tax Act 2009 section 841

"Participator" and "associate"

Section 841 defines the terms "participator" and "associate" as they are used in the related party rules for intangible fixed assets of close companies.

• A "participator" in a close company broadly means any person who has a share or interest in the capital or income of the company, as defined in the Corporation Tax Act 2010.
• A person who is merely a loan creditor of the company is not treated as a participator for these purposes.
• An "associate" of a participator includes relatives, business partners, trustees of settlements connected with the participator, and certain connected companies, as defined in the Corporation Tax Act 2010.
• These definitions are important because they determine whether a transaction involving intangible fixed assets falls within the related party rules, which can restrict the tax relief available.