{
  "url": "https://openlegislation.uk/finance-act-2014/schedule-33A/paragraph-2",
  "json_url": "https://openlegislation.uk/finance-act-2014/schedule-33A/paragraph-2.json",
  "legislation": "ukpga/2014/26",
  "legislation_title": "Finance Act 2014",
  "legislation_url": "https://openlegislation.uk/finance-act-2014",
  "path": "schedule/33A/paragraph/2",
  "kind": "paragraph",
  "number": "2",
  "heading": null,
  "text": "(1) A falls within this case if—\n(a) A and one or more other persons carry out activities between them that if carried out by a single person would cause that person to be a promoter within the meaning of section 235(2) or (3), and\n(b) each of the persons carrying out those activities is closely related to at least one other of those persons.\n(2) A person (“D”) is closely related to another person (“E”) if—\n(a) D is able to secure that E acts in accordance with D's wishes (or vice versa),\n(b) E typically acts in accordance with D's wishes,\n(c) it is reasonable to expect that E will act in accordance with D's wishes,\n(d) a third person is able to secure that D and E act in accordance with the third person's wishes,\n(e) D and E typically act in accordance with a third person's wishes,\n(f) it is reasonable to expect that D and E will act in accordance with a third person's wishes, or\n(g) the 50% investment condition is met in relation to D and E.\n(3) The 50% investment condition is met in relation to D and E if—\n(a) D has a 50% investment in E (or vice versa), or\n(b) a third person has a 50% investment in each of D and E.\n(4) Subsections (3) to (9) of section 259ND of TIOPA 2010 apply for the purposes of determining whether a person has a “50% investment” in another person, and references in those subsections to X% are to be read as references to 50%.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 33A inserted (with effect in accordance with s. 121(6) of the amending Act) by Finance Act 2021 (c. 26), Sch. 30 para. 10"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2014/26/schedule/33A/paragraph/2",
    "retrieved_at": "2026-10-29T09:07:29.129035+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}