Corporation Tax Act 2010 section 847

Associated persons

Section 847 defines who counts as "associated persons" for the purposes of the sale and lease-back rules on payments connected with transferred land.

  • Transferors in separate affected transactions are associated if they act in concert or their transactions are reciprocal, and any associate of either transferor is also associated.
  • Two or more companies are associated if they participate in, or were incorporated for the purposes of, a scheme for the reconstruction or amalgamation of companies.
  • Persons are associated if they fall within the wider definition of "associates" in section 882, which covers relatives, settlements, persons controlling bodies corporate, joint owners and similar relationships.
  • An "affected transaction" is one falling within sections 835 or 836 of the Corporation Tax Act 2010, or sections 681AA or 681AB of the Income Tax Act 2007, all of which deal with situations where a transferor or associate becomes liable for rent or other payments.

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