Income tax - whether certain rights conferred by the Companies Act 1993 could give rise to a 'shareholder decision-making right'

This Interpretation Statement concerns whether certain rights conferred by the Companies Act 1993 could give rise to a 'shareholder decision-making right' as defined in section YA 1 of the Income Tax Act 2007. This statement addresses an issue that has been raised by taxpayers and their advisers in the course of a number of private binding ruling applications.