Income Tax (Earnings and Pensions) Act 2003 section 554Z1

Interpretation: persons linked with A

Section 554Z1 defines who counts as a person "linked with A" for the purposes of the disguised remuneration rules in Part 7A of ITEPA 2003.

  • A person linked with A includes anyone who is or has been connected with A, including cohabiting partners treated as spouses or civil partners
  • Close companies in which A (or another linked person) is or has been a participator are linked with A
  • Non-UK resident companies that would be close companies if UK resident are also caught, where A or a linked person is or has been a participator
  • Any company that is a 51% subsidiary of such a close company (or deemed close company) is also treated as linked with A

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