Part 2 Notional Trade and Business of Indirect Partner
Finance Act 2018 (2018 c 3) | Legislation

Part 2 Notional Trade and Business of Indirect Partner

5

(1)     ITTOIA 2005 is amended as follows.

(2)     In section 847 (general provisions), after subsection (3) insert—

“(4)     For the purposes of this Part, a person is an indirect partner in a partnership (“the underlying partnershipâ€) if the person is a partner in—

(a)     a partnership which is a partner in the underlying partnership, or

(b)     any partnership which is an indirect partner in the underlying partnership by virtue of the preceding application of this subsection.â€

(3)     After section 852 insert—

“852A Notional trades: indirect partners

(1)     This section applies in relation to the notional trade of a partner in a firm if—

(a)     the firm consists of a partnership which is a partner or indirect partner in another partnership (“the underlying partnershipâ€),

(b)     the members of the underlying partnership carry on a trade (the “underlying tradeâ€),

(c)     the firm's trading profits or losses referred to in section 852(1) arise by virtue of profits or losses (“the underlying profits or lossesâ€) arising

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