Corporation Tax Act 2010 section 1068

Meaning of "participator" in sections 1064 to 1067

Section 1068 defines the term "participator" as it applies to the rules in sections 1064 to 1067 dealing with expenses and benefits provided by certain close companies that may be treated as distributions.

• For the purposes of sections 1064 to 1067, a "participator" has the same meaning as defined in section 454 of the Act, which deals with close companies.
• A participator broadly includes any person having a share or interest in the capital or income of the company, such as shareholders, loan creditors, or anyone with rights to acquire such interests.
• The definition is extended further by section 1069, which treats additional persons as participators beyond those caught by the standard definition.
• This wider definition matters because it determines whose expenses or benefits, when met by the company, could be reclassified as distributions for corporation tax purposes.