Section 451 — Corporation Tax Act 2010: Section 450: rights to be attributed etc

Section 450: rights to be attributed etc 451 1 This section applies for the purposes of section 450.

2 A person is treated as entitled to acquire anything which the person—

a is entitled to acquire at a future date, or b will at a future date be entitled to acquire.

3 If a person—

a possesses any rights or powers on behalf of another person (A), or b may be required to exercise any rights or powers on A's direction or behalf, those rights or powers are to be attributed to A.

4 There may also be attributed to a person all the rights and powers—

a of any company of which the person has, or the person and associates of the person have, control, b of any two or more companies within paragraph (a),

c of any associate of the person, or d of any two or more associates of the person.

5 The rights and powers which may be attributed under subsection (4)—

a include those attributed to a company or associate under subsection (3), but b do not include those attributed to an associate under subsection (4).

6 Such attributions are to be made under subsection (4) as will result in a company being treated as under the control of 5 or fewer participators if it can be so treated.