Part 2Income tax, corporation tax and capital gains tax_general
Double taxation arrangements
F357Double taxation relief
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
58UK residents and foreign partnerships
F11
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
In section 59 of TCGA 1992 (partnerships), insert at the end—
4
For the purposes of subsections (2) and (3) the members of a partnership include any person entitled to a share of capital gains of the partnership.
3
In section 858 of ITTOIA 2005 (resident partners and double taxation agreements), insert at the end—
4
For the purposes of this section the members of a firm include any person entitled to a share of income of the firm.
4
The amendments made by subsections (1) to (3) are treated as always having had effect.
5
For the purposes of the predecessor provisions, the members of a partnership are to be treated as having included, at all times to which those provisions applied, a person entitled to a share of income or capital gains of the partnership.
6
“The predecessor provisions” means—
a
section 153(4) and (5) of the Income and Corporation Taxes Act 1970 (c. 10) (as it had effect under section 62(2) of F(No.2)A 1987), and
b
sections 112(4) to (6) and 115(5) of ICTA.
F259UK residents and foreign enterprises
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .