C1Part 9Partnerships

Annotations:
Modifications etc. (not altering text)
C1

Pt. 9 modified (with effect as mentioned in Sch. 6 para. 6(2)-(7) to the amending Act) by Income and Corporation Taxes Act 1988 (c. 1) , s. 774D(4) as inserted by Finance Act 2006 (c. 25), s. 76, Sch. 6 para. 6(1)

Firms with a foreign element

857Partners to whom the remittance basis F1applies

1

This section applies if—

a

a firm carries on a trade wholly or partly outside the United Kingdom,

b

the control and management of the trade is outside the United Kingdom, and

F2c

section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to a partner for a tax year.

2

The partner's share of the profits of the trade arising in the United Kingdom is determined in accordance with sections 849 to 856.

3

The partner's share of the profits of the trade arising outside the United Kingdom is treated as relevant foreign income F3....