Related Commentary  Related HMRC Manuals

162(1)  Subsection (2) applies for the purposes of sections 148(2)(b) and (3)(b) and 175(2)(b).

162(2)  A person (“Q”) is indirectly participating in the management, control or capital of each of the affected persons at the time of the making or imposition of the actual provision if–

(a)the actual provision relates, to any extent, to financing arrangements for one of the affected persons (“B”),

(b)B is a body corporate or firm,

(c)Q and other persons acted together in relation to the financing arrangements, and

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