There is a separate set of provisions (at ITTOIA 2005, s. 850D), which apply where a partnership consists only of non-individuals, with the persons who might otherwise have been partners acting through those non-individuals. Typically, this would be a partnership of companies each wholly owned by an individual who one might assume would otherwise have been a partner, directly.

Gateway provisions

These provisions apply if (ITTOIA 2005, s. 850D(1)):

(a)an individual, A, personally performs services for the firm at any time during a period of account;

(b)if A had been a partner throughout the period of account, A would have had a profit under the calculation under ITTOIA 2005, s. 849;

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