Paragraph 19

(1)

For the purposes of this Schedule a person (“P”) is a “controlling member” of a partnership at any time when the person has a right to a share of more than half the assets, or of more than half the income, of the partnership.

(2)

For that purpose there are to be attributed to P any interests or rights of—

(a)

any individual who is connected with P (if P is an individual), and

(b)

any body corporate that P controls.

(3)

An individual is “connected” with P if the individual is—

(a)

P's spouse or civil partner;

(b)

a relative of P;

(c)

the spouse or civil partner of a relative of P;

(d)

a relative of P's spouse or civil partner, or

(e)

the spouse or civil partner of a relative of P's spouse or civil partner.

(4)

In sub-paragraph (3) “relative” means brother, sister, ancestor or lineal descendant.

(5)

P controls a body corporate (“B”) if P has power to secure—

(a)

by means of the holding of shares or the possession of voting power in relation to B or any other body corporate, or

(b)

as a result of any powers conferred by the articles of association or other document regulating that or any other body corporate,

that the affairs of B are conducted in accordance with P's wishes.