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HMRC internal manual

International Manual

HM Revenue & Customs
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DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

Definition of control

Articles 10(1)(d)(ii), 11(8)(b) & 12(7)(b) defines ‘control’ as meaning‘control’ for UK tax purposes. There are definitions of control for variousCorporation Tax purposes in ICTA 1988/S416 and S840. These indicate that in general aperson has control of a company if he has the power to secure that the affairs of thecompany are conducted in accordance with his wishes. This may be achieved in various ways,but a person is likely to be regarded as controlling a company if, for example, hepossesses or is entitled to acquire

  • the greater part of the voting power in the company, or
  • the greater part of the share capital in the company, or of the issued share capital of the company.