Commentary

D1.771 Loan relationships—Partnerships, charities and insurance companies

Corporate tax
Corporate tax | Commentary

D1.771 Loan relationships—Partnerships, charities and insurance companies

Corporate tax | Commentary

D1.771 Loan relationships—Partnerships, charities and insurance companies

Partnerships

Where one or more of the partners in a partnership is a company and one or more of the partners is not, two separate computations of the partnership profits have to be made, one using income tax rules and one using corporation tax rules (see D7.401). Where a money debt is owed by or to the partnership, no debits or credits in relation to that debt (or any loan relationship arising from it) are brought into the partnership corporation tax computation1.

Instead, each company partner is required to bring its share of the debits and credits arising on the partnership's loan relationships and other money debts into account in computing its loan relationship profits. Each company partner's share of the debits and credits

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