Commentary

I6.222 Dispositions of partnership property

IHT, trusts and estates

I6.222 Dispositions of partnership property

I6.222 Dispositions of partnership property

For the purposes of the business of a partnership, each partner is the agent both of the partnership itself and of each of his co-partners1. Therefore, if a partnership makes a gratuitous disposition of partnership property2, which is not, for example, allowable in computing its taxable profits3 (see I3.154), or otherwise excluded from being a transfer of value4, each of the partners must, prima facie, be regarded as making a transfer of value.

For further information on exclusion relating to transfers of value see I3.141–I3.159.

However, as a partner does not have a specific interest in any

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