

The Attribution Regime for Individuals was introduced for companies with accounting periods commencing on or after 6 April 2008.
The ARI applies to all resident individuals with an interest in a relevant company.
Resident individuals with an interest in a relevant company will be charged to income tax on their share of the attributed profits from that company. This will in essence remove the corporate veil for income tax purposes as individuals will be taxed directly as if they had received the income attributable to their share of the annual profits of a relevant company. This is known as the attributed income.
The Division has issued the following documents relating to the ARI
| Document Name | Number | Date of issue |
|---|---|---|
| GN 42 - Overview of the Attribution Regime for Individuals | GN 42 | 11 August 2008 |
| GN 41 - Attribution Regime for Individuals | GN 41 | 4 August 2008 |
| Income Tax (Attributed Profits) (De Minimis Limit) Regulations 2008 | SD 241/08 | 21 May 2008 |
| Income Tax (Attributed Profits) (Relevant Company) Order 2008 | SD 240/08 | 21 May 2008 |
| Income Tax (Attributed Profits) (Groups) Regulations 2008 | SD 239/08 | 21 May 2008 |
| Income Tax (Attributed Profits) (Certificate) Order 2008 | SD 238/08 | 21 May 2008 |
| Income Tax (Distributable Profit) (Prescribed Deductions) Order 2008 | SD 237/08 | 21 May 2008 |
| Income Tax (Calculation of Attributed Profit) Regulations 2008 | SD 236/08 | 21 May 2008 |
| Income Tax (Attributed Profits) (Temporary Taxation) Order 2007 | SD 928/07 | 11 December 2007 |
