Commentary

D1.629G Corporate intangible regime and corporate partnerships

Corporate tax
Corporate tax | Commentary

D1.629G Corporate intangible regime and corporate partnerships

Corporate tax | Commentary

D1.629G Corporate intangible regime and corporate partnerships

There is no specific legislation within the corporate intangible regime which deals with partnerships. The treatment of debits and credits in relation to an intangible asset held by a partnership which has a corporate partner would follow the 'look through' approach on general principles1 (see B7.401). Although there is no specific case law looking at this point, the 'look through' treatment is consistent with the discussion of the treatment of intangibles in Bloomberg Inc discussed below2.

If an asset is transferred between the partnership and a corporate partner the transfer is treated as

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