Corporation Tax Act 2010 section 169

Application and interpretation of sections 170 to 182

Section 169 introduces the rules in sections 170 to 182 and defines the key terms used in those sections for working out the proportion of profits or assets to which a company would be beneficially entitled.

• Sections 170 to 182 apply when determining the proportion of profits or assets to which company A would be beneficially entitled under the tests in sections 165(2) or 166(2) at any given time.
• "Arrangements" means arrangements of any kind, whether written or not, but excludes conditions or requirements imposed by or agreed with a Minister of the Crown, the Scottish Ministers, a Northern Ireland department, or a statutory body.
• "Distribution rights" covers rights to dividends, interest, or assets on a winding up, while "participating equity holders" means those equity holders of company B who would receive a profit distribution or participate in a notional winding up.
• A "statutory body" is an entity established by or under statute to carry out statutory functions (other than a company as defined by the Companies Act 2006), though the Treasury may by order specify whether a particular body is or is not a statutory body for these purposes.