Corporate partners

Recent tax publications and websites have featured extended trails of correspondence on corporate partners in partnerships (whether general partnerships limited partnerships or limited liability partnerships).

In considering the position of such partnerships (mainly but not exclusively trading partnerships) and particularly those with a large number of partners the practice – bearing in mind CTA 2009 s 1262 and related sections – is that the allocation of profits and losses other than perhaps specifics such as loan relationships debits and credits and any debits and credits arising in respect of derivative contracts is on a pro-rata apportionment of tax adjusted profits (cf ITTOIA 2005 s 25 and s 850).

However unless I have misinterpreted the situation ...