Corporation Tax Act 2010 section 262

Nominees

Section 262 explains how loans, securities and shares held through nominees or bare trustees are treated for the purposes of Part 5 of the Corporation Tax Act 2010.

• Where a nominee makes, receives or disposes of a loan on behalf of a person, the loan is treated as if that person had made, received or disposed of it directly.
• Where a nominee subscribes for, is issued, acquires, holds or disposes of securities or shares on behalf of a person, those actions are treated as carried out by that person directly.
• A bare trustee acting on behalf of a person is treated in the same way as a nominee, so all the same rules apply.
• The effect is to look through nominee and bare trust arrangements so that the underlying beneficial owner is regarded as the party to the transaction.