D1.629G Corporate Intangible Regime And Corporate Partnerships

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Commentary

Corporate tax

There is no specific legislation within the corporate intangible regime which deals with partnerships. The treatment of debits and credits in relation to an intangible asset held by a partnership which has a corporate partner would follow the 'look through' approach on general principles¹ (see B7.401). Although there is no specific case law looking at this point, the 'look through' treatment is consistent with the discussion

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D1.629G Corporate intangible regime and corporate partnerships

Corporate tax

B3.340A Hire purchase of plant and machinery and similar contracts

B4.130 Summary of OECD guidelines on arm's length principle

A4.214 Claims following further assessments—income tax and capital gains tax

I3.750 POAT—introduction to existing arrangements

C2.501A Compensation and capital gains tax—overview

B5.812A Particular charitable bodies

B5.820 Charity's profits of trade—general liability to income tax

E8.271 Liability for Class 1A contributions

C2.201 Allowable expenditure for capital gains—overview

D2.250 Group relief—limited rights, variable rights and options attaching to ordinary shares

C2.108 Contingent liabilities

I8.335 Valuation on death of partner in service

E4.115 Employment income—place of performance of duties

D1.1061 Substantial shareholding exemption—interaction with other reliefs

I11.215 IHT accounts—excepted settlements

B5.846 Charities and close companies

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

B2.202 Capital receipts

I5.1304 Beneficiary with contingent interest

E6.102K Statutory residence test—the definition of a 'home'

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D1.629G Corporate intangible regime and corporate partnerships

Corporate tax

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