Introduction Overview Section 27: Attribution to persons of rights and powers of their partners
112.This section modifies the rule in section 25(4) and (5) about “control”. It is based on section 13(4), (4A), (4B) and (4C) of ICTA.
113.Section 451 attributes to a person rights that belong to any associate of that person. In accordance with section 448, “associate” includes a (business) partner.
114.This section relaxes the rule about attributing a partner’s rights unless tax planning arrangements are in place.