Corporation Tax Act 2010 section 27

Attribution to persons of rights and powers of their associates

Section 27 modifies the rules about "control" of a company by relaxing the way in which business partners' rights are attributed to each other, unless tax planning arrangements are involved.

• When determining whether a person controls a company, the rights and powers held by that person's associates are normally attributed to them under Section 451.
• An "associate" is defined broadly and includes business partners, in accordance with Section 448.
• Section 27 provides a relaxation of this attribution rule specifically for business partners, so that a partner's rights are not automatically treated as belonging to the other partners for the purpose of determining control.
• This relaxation does not apply where tax planning arrangements are in place — in such cases, the normal attribution of partners' rights continues to apply.