Section 18J — Corporation Tax Act 2010: Association through a trustee

Association through a trustee 18J 1 Subsection (2) applies if—

a two companies (“ A ” and “ B ”) are controlled by the same person by virtue of rights or powers (or both) held in trust by that person, and b there is no other connection between A and B.

2 In determining for the purposes of this Part whether A and B are associated with each other, the rights and powers mentioned in subsection (1)(a) are ignored.

3 In subsection (1)—

a “ control ” has the same meaning as in section 18E(4),

b “ connection ” includes a connection in the past as well as a connection in the present, and c the reference to a connection between A and B includes any dealings between them.