Corporation Tax Act 2009 section 931T

Meaning of "payer", "recipient" and "relevant person"

Section 931T defines three key terms — "payer", "recipient" and "relevant person" — used throughout Part 9A when dealing with distributions between companies.

• The "payer" is simply the company that makes a distribution
• The "recipient" is the company that receives a distribution
• A "relevant person" is either the recipient company itself or any person connected with that company
• The "relevant person" definition is particularly important for the anti-avoidance provisions in Part 9A