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Partnership problem

01 May 2012
Issue: 4351 / Categories: Forum & Feedback , Capital Gains , Companies
An otherwise unconnected individual and a limited company own a newly built commercial building which they let out. They are registered as partners for VAT purposes

Mr A and X Limited have acquired jointly (50% each) the freehold of a newly built commercial property which is to be held as an investment and rented out. There is no other connection between Mr A and X Limited and the tenants.

For tax purposes we intend to treat this as a joint letting so that 50% of income and expenses are treated as income and expenses of the relevant parties.

However because of the VAT implications it has been necessary to register Mr A and X Limited as partners for VAT purposes.

There has been substantial qualifying expenditure for capital allowances on plant and integral features. The question is how is this to be dealt with by the joint owners?

Do we attribute half the qualifying expenditure as having been made by each partner and they then claim allowances according to their own circumstances?

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