Income Tax Act 2007

167 Employees, directors and partners

(1) An individual is connected with the issuing company if the individual—

(a) is an employee of—

(i) the issuing company,

(ii) any subsidiary of the issuing company, or

(iii) a partner of the issuing company or any of its subsidiaries,

(b) is a partner of—

(i) the issuing company, or

(ii) any subsidiary of the issuing company, or

(c) subject to section 168, is a director of—

(i) the issuing company,

(ii) any subsidiary of the issuing company, or

(iii) a company which is a partner of the issuing company or any of its subsidiaries.

(2) In subsection (1) “subsidiary”, in relation to the issuing company, means a company which at any time in period A is a 51% subsidiary of the issuing company, whether or not it is such a subsidiary while the individual or associate concerned is such an employee, partner or director as is mentioned in that subsection.

(3) For the purposes of this section and sections 168 and 169, in the case of an individual (“A”) who is both a director and an employee of a company—

(a) references (however expressed) to A in A’s capacity as a director of the company include A in A’s capacity as an employee of the company, but

(b) (apart from that) A is to be treated as a director, and not as an employee, of the company.