Taxation (International and Other Provisions) Act 2010 section 463

Whether a person is generally a "related party" of another

Section 463 defines when one person is considered a "related party" of another person for the purposes of the corporate interest restriction rules.

• Two persons are related parties throughout any period in which they are consolidated together for accounting purposes, whether required to be, or actually included in, group accounts
• They are related parties on any day where, within a six-month window beginning or ending on that day, one participates in the management, control or capital of the other, or a common person participates in both
• They are related parties on any day where the 25% investment condition is met — meaning one holds a 25% investment in the other, or a third person holds a 25% investment in each of them
• A special exception applies for securitisation companies: the participation condition does not make parties related merely because a securitisation company is held by a trustee of a settlement and the other party is a settlor of that settlement