Taxes Consolidation Act 1997 section 1009

Partnerships involving companies

Section 1009 sets out how a company that is a partner in a partnership is charged to corporation tax on its share of the partnership profits, losses, capital allowances, and balancing charges.

• A company partner's share of partnership profits (excluding chargeable gains) is treated as arising from a separate trade — the "several trade" — and is charged to corporation tax accordingly.
• Where the partnership accounting period does not coincide with the company's corporation tax accounting period, the company's profit or loss share must be time-apportioned to fit its own accounting periods.
• The company's share of partnership capital allowances (joint allowances) and balancing charges (joint charges) is time-apportioned to its accounting periods and treated as a trading expense or trading receipt of its several trade.
• A joint allowance for a tax year does not include any capital allowance brought forward from a previous year — only current-year allowances qualify as a deductible trading expense of the company partner.