The calculation/computation of gains that are attributable to a partner are triggered not only on a disposal of a partnership asset (B7.406), but also when there is a change in the partnership sharing ratio (see below). In general such computations will be a no gain/no loss transaction as the deemed consideration will be equal to the base cost.
However there is likely to be a chargeable gain/loss where there is a change in ratio and a:
- Ìý
•ÌýÌýÌýÌý revaluation of an asset in the partnership accounts, see below
- Ìý
•ÌýÌýÌýÌý direct payment, not reflected in the partnership accounts, is made between two partners, see below
Where, as will often be the case, the partnership owns more than one asset within the charge to capital gains tax, it will be necessary to make a separate computation in respect of each asset.
Variation of existing partnership sharing ratios
A partner is treated as having disposed of part of their share of the partnership assets if the sharing ratios are varied such that they have a smaller interest.
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Web page updated on 17 Mar 2025 17:21