Review of FA 2010 measures by Gary Heynes and Michael Flaherty
Relevant persons
The definition of relevant persons was introduced in FA 2008 and means that it is no longer just the individual themselves who is able to make a remittance on which they are taxable but also someone 'connected' to them defined as relevant person. This can include minor children a trust of which they are a settlor or a company of which they are a participator.
While it is clear that a company of which the remittance basis user is a direct participator is a relevant person some clarification was needed on subsidiary companies. A specific definition of 51% subsidiaries of companies which would be close companies if they were resident in the UK has been inserted in ITA 2007 s 809M(2)(f). FA 2009 had already amended ITA 2007 s 809M(2)(e) to...
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Review of FA 2010 measures by Gary Heynes and Michael Flaherty
Relevant persons
The definition of relevant persons was introduced in FA 2008 and means that it is no longer just the individual themselves who is able to make a remittance on which they are taxable but also someone 'connected' to them defined as relevant person. This can include minor children a trust of which they are a settlor or a company of which they are a participator.
While it is clear that a company of which the remittance basis user is a direct participator is a relevant person some clarification was needed on subsidiary companies. A specific definition of 51% subsidiaries of companies which would be close companies if they were resident in the UK has been inserted in ITA 2007 s 809M(2)(f). FA 2009 had already amended ITA 2007 s 809M(2)(e) to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
