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HMRC internal manual

Company Taxation Manual

Corporation Tax: small profits relief: associated companies - attribution of rights and powers of nominees

The rights and powers of a person’s nominee are always attributed to that person. This means any rights or powers which another person possesses or may be required to exercise on the direction or on behalf of that person (CTA10/S451 (3). This rule contrasts with the rule applying to the attribution of the rights and powers of associates under CTA10/S451 (4) - see CTM03750.

Thus nominees are always looked through to the beneficial owners when determining control. This does not, however, mean that a nominee is not a participator in a company by reason of legally holding shares in it.

For the meaning of participator see CTM60107.