{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-259NC",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-259NC.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/259NC",
  "kind": "section",
  "number": "259NC",
  "heading": "Related persons",
  "text": "(1) Two persons are “related” on any day that—\n(a) they are in the same control group (see section 259NB), or\n(b) the 25% investment condition is met in relation to them.\n(2) The 25% investment condition is met in relation to a person (“A”) and another person (“B”) if—\n(a) A has a 25% investment in B, or\n(b) a third person has a 25% investment in each of A and B.\n(3) Section 259ND applies for the purposes of determining whether a person has a “25% investment” in another person.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 6A inserted (with effect in accordance with Sch. 10 paras. 18-21 of the amending Act) by Finance Act 2016 (c. 24), Sch. 10 para. 1"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "S. 259NC applied by 2010 c. 4, s. 356OT(6) (as inserted (with effect in accordance with s. 81 of the amending Act) by Finance Act 2016 (c. 24), s. 77(1) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2)))"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "S. 259NC applied by 2007 c. 3, s. 517U(6) (as inserted (with effect in accordance with s. 82 of the amending Act) by Finance Act 2016 (c. 24), s. 79(1) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2)))"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/259NC",
    "retrieved_at": "2026-10-29T09:10:17.008829+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."
}