Taxation (International and Other Provisions) Act 2010 section 462

Expressions relating to "related parties": introduction

Section 462 introduces the framework of rules that determine when a person is a "related party" of another person for the purposes of the corporate interest restriction rules in Part 10.

• The general definition of "related party" is set out in section 463, which applies broadly to any amount and is supported by supplementary rules in sections 464 and 465.
• Sections 466 and 467 provide additional rules that can treat persons as if they were related parties of each other, but only for certain specific purposes.
• Sections 468 to 472 provide rules that can treat persons as if they were not related parties of each other, again only for certain specific purposes, and these rules take priority over sections 466 and 467.
• Where there is a conflict between the rules that deem persons to be related parties and the rules that deem them not to be, the "not related" rules in sections 468 to 472 prevail.