I12.303 Partnerships

I12.303 Partnerships

Although there remain a number of grey areas and untested points, it can be expected that the HMRC will apply tests of reasonableness and commerciality. For example, if a husband and wife and their son are in partnership, with the son making the greatest contribution to the profits, his parents may wish to transfer part of their capital accounts to him in recognition of his additional efforts. Provided the transfer is commercial in the light of the additional contribution made by the son, this would not amount to a gift with the result that the reservation of benefit

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