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Corporation Tax Act 2010

Section 445: Section 444: registered pension schemes

1345.This section supplements section 444; it is concerned with shares held on trust for registered pension schemes. It is based on section 414(7) of ICTA.

1346.Subsection (1) is based on the full-out words at the beginning and end of section 414(7) of ICTA. In summary, a registered pension scheme within subsection (1) is treated as a non-close company.

1347.Subsection (2) is based on the “unless”-clause in the full-out words at the beginning of section 414(7) of ICTA. It is the first part of an exception to subsection (1). It focuses on the individuals for whose benefit the scheme is established.

1348.Subsection (3) is based on section 414(7)(a) to (c) of ICTA. It is the second part of the exception to subsection (1). It focuses on the companies of which the individuals in subsection (2)(a) are or were directors or employees.

1349.“Associate” and “associated company” appear for the first time in subsection (3). Their definitions are signposted in subsection (4).

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