Inheritance Tax Act 1984 section 102

Interpretation

Section 102 defines key terms used throughout Part IV of the Inheritance Tax Act 1984, which deals with close companies and the tax charges that can arise from transactions involving them.

• A "close company" includes any company that would qualify as close under the Corporation Tax Acts, even if the company is not resident in the United Kingdom
• A "participator" means any person with a stake in a company as defined by section 454 of the Corporation Tax Act 2010, but specifically excludes anyone who qualifies only because they are a loan creditor
• A "qualifying interest in possession" takes its meaning from section 59 of the Inheritance Tax Act 1984, which sets out the conditions for certain trust interests to be treated as part of the beneficiary's estate
• A person's rights and interests in a company are broadly defined to include their entitlement to assets that would be available for distribution on a winding up or in any other circumstances