Part 9 Partnerships

Firms with a foreign element

857 Partners to whom the remittance basis may apply

(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

(c) a partner who is a UK resident individual—

(i) meets condition A or B in section 831 (conditions to be met for income to be charged on the remittance basis), and

(ii) makes a claim to that effect 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 for the purposes of this Act (see Part 8).