http://www.legislation.gov.uk/ukpga/2010/8/section/159Taxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2025-04-29Expert Participation2025-03-20 Part 4CHAPTER 21591Subsection (2) applies for the purposes of—asections 148(2) and (3), 154(5), 175(2) and 204(4),bin Part 2, section 132(7), ...cin Part 5, section 219(2) , ...din Part 6A, section 259NB(4) , ... , and ein Part 10, section 463(4), ...f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2A person (“P”) is indirectly participating in the management, control or capital of another person (“A”) at a particular time if P would be directly participating in the management, control or capital of A at that time if the rights and powers attributed to P included all the rights and powers mentioned in subsection (3) that are not already attributed to P for the purpose of deciding under section 157 whether P is directly participating in the management, control or capital of A.3The rights and powers referred to in subsection (2) are—arights and powers which P is entitled to acquire at a future date,brights and powers which P will, at a future date, become entitled to acquire,crights and powers of persons other than P so far as they are rights or powers falling within subsection (4),drights and powers of any person with whom P is connected (see section 163), anderights and powers which would be attributed by subsection (2) to a person with whom P is connected were it being decided under that subsection whether that connected person is indirectly participating in the management, control or capital of A.4Rights and powers fall within this subsection so far as they—aare required, or may be required, to be exercised in any one or more of the following ways—ion behalf of P,iiunder the direction of P, oriiifor the benefit of P, andbare not confined, in a case where a loan has been made by one person to another, to rights and powers conferred in relation to property of the borrower by the terms of any security relating to the loan.5In subsections (3)(c) to (e) and (4), the references to a person's rights and powers include references to any rights or powers which the person either—ais entitled to acquire at a future date, orbwill, at a future date, become entitled to acquire.6In paragraph (e) of subsection (3), the reference to rights and powers which would be attributed to a connected person includes a reference to rights and powers which, by applying that paragraph wherever one person is connected with another, would be so attributed to the connected person through a number of persons each of whom is connected with at least one of the others.7References in this section—ato rights and powers of a person, orbto rights and powers which a person is or will become entitled to acquire,include references to rights or powers which are exercisable by that person, or (when acquired by that person) will be exercisable, only jointly with one or more other persons.S. 159(1)(d) and word inserted (15.9.2016) by Finance Act 2016 (c. 24), Sch. 10 para. 13(b)S. 159(2) applied by 2010 c. 4, s. 356OT(7) (as inserted (with effect in accordance with s. 81 of the amending Act) by Finance Act 2016 (c. 24), s. 77(1) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2)))Word in s. 159(1)(c) omitted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by virtue of Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 16(a)S. 159(1)(e) and word inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 16(b)Word in s. 159(1)(d) inserted (with effect in accordance with s. 20(12) of the amending Act) by Finance Act 2025 (c. 8), s. 20(8)(a)(12)S. 159(2) applied by 2007 c. 3, s. 517U(7) (as inserted (with effect in accordance with s. 82 of the amending Act) by Finance Act 2016 (c. 24), s. 79(1) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2)))Pt. 4 excluded (1.10.2011) by Postal Services Act 2011 (c. 5), s. 93(2)(3), Sch. 2 para. 6(2); S.I. 2011/2329, art. 3Word in s. 159(1)(b) omitted (15.9.2016) by virtue of Finance Act 2016 (c. 24), Sch. 10 para. 13(a)Pt. 4 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)Ss. 158-163 applied (with modifications) (with effect in accordance with s. 116(1) of the amending Act) by Finance Act 2015 (c. 11), s. 106(7)(b)Pt. 4 excluded (1.4.2012) by Budget Responsibility and National Audit Act 2011 (c. 4), s. 29, Sch. 4 para. 3(2); S.I. 2011/2576, art. 5Pt. 4 excluded (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 129(11) (with s. 147, Sch. 17)Word in s. 159(1)(d) omitted (with effect in accordance with Sch. 3 para. 7 of the amending Act) by virtue of Finance Act 2019 (c. 1), Sch. 3 para. 6(3)(a)S. 159(1)(f) and word omitted (with effect in accordance with s. 20(12) of the amending Act) by virtue of Finance Act 2025 (c. 8), s. 20(8)(b)(12)