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.
Introduction Overview Section 27: Attribution to persons of rights and powers of their partners