Commentary

B6.706 ATED—person liable and nature of liability

Business tax
Business tax | Commentary

B6.706 ATED—person liable and nature of liability

Business tax | Commentary

B6.706 ATED—person liable and nature of liability

The person liable to pay ATED is the 'chargeable person', by which is meant:

  1.  

    (a)     where a company is entitled to an SDI, the company

  2.  

    (b)     where a partnership with a corporate member is entitled to an SDI, the responsible partners1

The responsible partners for the purposes of (b) above are all the members of the partnership from the first day of the chargeable period when the partnership meets the ownership condition (see B6.705) with respect to the SDI2. The liability of the responsible partners to pay tax is joint and several3.

The chargeable person for the different types of collective investment schemes is as follows:

  1.  

    (i)     if the collective investment scheme is a unit trust scheme, the trustee of the scheme

  2.  

    (ii)     if the collective investment scheme is an open-ended investment company, the body corporate referred to in FSMA 2000, s 236(2)

  3.  

    (iii)     in relation to an EEA UCITS which is

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