The treatment of the deemed employment payment on the MSC – whether a company or a partnership, and whether liable to income or corporation tax – is very similar to that applying to deemed payments under the intermediaries (IR35) legislation (as to which, see Division E4.10).
Deduction in computing profits for unincorporated entities
ITTOIA 2005, s 164A deals with the treatment of the amount in computing the profits of an MSC that is a partnership (although it is specifically disapplied where the cash basis
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