B7.410 Capital gains treatment of partnership annuities

Business tax
Commentary

A lump sum paid to a partner on retirement from the partnership represents consideration for the disposal of their share in the partnership assets (possibly including goodwill) and will be dealt with in accordance with the practice described in B7.408 at 'Payments for assets between partners'. Similarly, where the partnership buys a purchased life annuity for a retiring partner, the cost of the annuity will be consideration for the disposal of their share in the partnership assets.

Where the consideration for the disposal of an asset includes the capitalised value of a right to a series of payments in the nature of income, that capitalised value enters into the computation of the capital gain on that disposal

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Home / Simons-Taxes /Business tax /Part B7 Partnerships /Division B7.4 Computation of partnership income and gains /Partnership capital gains / B7.410 Capital gains treatment of partnership annuities