Where conditions A–C (see ¶289-455) apply, there is taken to be a connection between the company partner and each company partner (including the company partner itself) that has a debtor or creditor relationship under Condition C as a result of one of them having control of the other for the purposes of s. 466(2)) and the provisions of CTA 2009, Pt. 5 apply accordingly.

In other words, where a company partner controls a partnership, it is treated as connected to all company partners including itself for the purposes of CTA 2009, Pt. 5.

This means that the partner:

must use the mandatory accruals or amortised cost basis;

cannot have relief for impairment losses;

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