Income Tax Act 2007 section 719A

Other definitions

Section 719A defines three key terms — "closely-held company", "nominee" and "participator" — used throughout the settlements legislation chapter dealing with income arising under certain arrangements.

  • A closely-held company is one that is either a close company for corporation tax purposes or would be close if the exclusion for non-UK resident companies were disregarded.
  • A nominee is someone who holds rights or powers on behalf of an individual, or who can be required to exercise rights or powers at that individual's direction.
  • A participator takes its meaning from corporation tax legislation and broadly covers anyone who has a share or interest in a company's capital or income.
  • These definitions are central to determining whether the anti-avoidance settlements rules apply to arrangements involving companies and intermediaries.

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