835B Meaning of associated

Summary

Transfer pricing rules apply to certain arrangements between persons who are associated. This section deals with the meaning of “associated”.

Details

(1) Persons are associated if one person participates in the management, control or capital of another person or the same person is participating in the management, control or capital of both persons. The controlled person in each case must be a company. Associated persons are mainly companies but, for example, an individual who is a controlling shareholder of a company could be an associated person of that company.

(2) A company will be treated as controlled by an individual if it is controlled by the individual and persons connected with the individual. A person is connected with an individual if that person is a “relative” of that individual within the meaning of section 433(3)(a).

Relevant Date: Finance Act 2019