Taxation of Chargeable Gains Act 1992 Schedule 1A paragraph 10

Attribution of rights and interests

Section 10 of Schedule 1A sets out how a person's investment in a company is assessed by attributing the rights and interests of connected persons, and defines who counts as a connected person for this purpose.

• When determining whether a person holds a 25% or more investment in a company, the rights and interests of all connected persons must be aggregated with theirs.
• Being parties to a normal commercial loan does not, by itself, make two persons connected for these purposes.
• The definition of connected persons is narrower than the standard tax definition — it covers only lineal ancestors and lineal descendants of the individual, or of their spouse or civil partner.
• Certain broader provisions in the standard connected persons rules (such as those relating to partners and trustees) are specifically disapplied.