Legislation – Finance Act 2025
Part 1Income tax, capital gains tax and corporate taxes
International matters
22Advance pricing agreements: indirect participation in financing cases
(1)
In section 158 of TIOPA 2010 (which sets out how to read references to indirect participation for the purposes of, among other provisions, provisions relating to advance pricing agreements under Part 5 of that Act)—
(a)
in subsection (4), omit paragraph (c) (but not the “and” at the end of that paragraph), and
(b)
“(5)
For the purposes of section 219(2) (which is in Part 5), a person is indirectly participating in the management, control or capital of another person only if any of sections 159 to 162 so provide.”
(2)
In section 161 of that Act (indirect participation in financing cases)—
(a)
in subsection (1), at the end insert “and, in Part 5, section 219(2)”
, and
(b)
in the heading, for “and 175” substitute “, 175 and 219(2)”
.
(3)
In section 162 of that Act (indirect participation in further financing cases)—
(a)
in subsection (1), at the end insert “and, in Part 5, section 219(2)”
, and
(b)
in the heading, for “and 175” substitute “, 175 and 219(2)”
.
(4)
In section 219(4) of that Act (which sets out how to interpret references to associates by referring to, among other provisions, provisions in Part 4 of that Act that explain the meaning of indirect participation), for “and 160(1)” substitute “, 160(1), 161(1) and 162(1)”
.
(5)
The amendments made by this section are treated as always having had effect.