Readers' forum: One way or another

I act for a partnership which operates from premises that were previously owned by some but not all of the partners. The owners of the property are subject to a substantial breakage charge by the mortgage lenders on the sale of the property last year. This will create a large loss on rents for each individual during their final year of ownership. Some of the owners have other properties so will be able to use the losses against ongoing rental income. Others only had their interest in the property used by the partnership. However the trading partnership receives rent from subletting part of the trading premises which is split out and reported as rent through the partnership return.

HMRC’s manuals state that rents received as a member of a partnership are dealt with separately from rents received in a personal capacity (PIM1020). This seems to contradict the requirement to...