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Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

Commentary on Sections

Part 4: Transfer pricing

Chapter 2: Key interpretative provisions
Section 158: Indirect participation: defined by sections 159 to 162

327.This section lists the meanings which apply for each reference to indirect participation in the Act. It is based on section 808B(9) of, and paragraphs 4(2), 4A(1) and (2) and 6(4C) of Schedule 28AA to, ICTA and section 85(6) of FA 1999.

328.Sections 159 to 162 set out four possible meanings of indirect participation in the management, control or capital of another person. Any particular reference to indirect participation has two or three of those meanings.

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