Corporation Tax Act 2010 section 708

Rights to be attributed for the purposes of section 707

Section 708 sets out rules for attributing rights and powers between connected persons when determining whether a company is under the control of five or fewer participators for the purposes of the unpaid corporation tax recovery provisions in section 707.

• Future rights to acquire anything count as present rights — if a person is entitled now or will become entitled in the future to acquire something, they are treated as already having that entitlement.
• Rights or powers held or exercised on behalf of another person, or at that person's direction, are attributed to that other person rather than the holder.
• A person may also be credited with all the rights and powers of any company they control (alone or with associates), of any associate, or of any combination of such companies and associates.
• These attribution rules must be applied in whatever way results in the company being treated as controlled by five or fewer participators, if that outcome is possible.