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HMRC internal manual

Oil Taxation Manual

HM Revenue & Customs
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Oil contractors ring fence: associated person

The definition of associated person is widely drawn, see CTA2010\S356LB. It includes the contractor themselves and any person who is currently, or has at some time, been connected with the contractor. Connected is defined in CTA2010\S1122.

Associated person also includes those who act, or have acted, together with the contractor to provide a service and anyone currently connected to anyone already included in the definition.

Acting together has a very wide meaning as noted in INTM413180 where the same phrase is used in the application of TIOPA2010/S161 and TIOPA2010/S162 to the financing arrangements of a company or partnership.

It should be possible for a group to identify where a past group relationship has existed either from its own records or from available general information in the trade press. Details of occasions where a person has in the past acted together with a contractor outside of a group relationship may be harder to identify. LB Oil and Gas accept that it is unreasonable for a contractor to search records beyond a normal retention period if there have been no occasions in more recent periods of the same groups acting together in the provision of a service