Income Tax (Trading and Other Income) Act 2005 section 103

Connected persons and property arrangements

Section 103 defines what "connected persons" and "property arrangements" mean for the purposes of the reverse premiums rules in sections 99 to 102.

• This section provides key definitions that apply across all the reverse premium provisions (sections 99 to 102).
• Two persons are treated as connected if they are connected at any time during the period when the property arrangements are being entered into, using the general connected persons definition in section 878(5) of the Act.
• "Property arrangements" is defined broadly to cover not just the property transaction itself, but also any related arrangements made before, at the same time as, or after the transaction.
• The wide definition of property arrangements ensures that all associated dealings surrounding a property transaction are captured, preventing avoidance through the timing or structuring of connected arrangements.