Explanatory Notes

Income Tax (Trading and Other Income) Act 2005

2005 CHAPTER 5

24 March 2005

Commentary on Sections

Part 2: Trading income

Chapter 12: Trade profits: valuation of stock and work in progress
Section 179: Connected persons

739.This section provides a definition of connected persons for the stock valuation sections. It is based on section 100(1F) of ICTA.

740.This section is one of the exceptions to the general rule in section 847 that a firm is not to be regarded for tax purposes as a separate entity. If a firm is connected with the seller or purchaser of its stock, section 177 (rather than section 176) applies but the firm may make an election under section 178.

741.The definition includes references to bodies corporate because the tax liability of a person charged to income tax may be affected by a transaction involving a company.