290-935 Corporation tax restriction on transferring relief
The provisions contained in CTA 2010, Pt. 22, Ch. 3 are designed to prevent a company adjusting its share in the profits or loss of a partnership by means of a payment.
These provisions apply to a company (A) which carries on a trade in partnership and where there are arrangements under which:
(a)in relation to all or part of A’s share in the loss of the partnership company, A, or a person connected with A, receives any payment or other benefit (excluding, in certain instances, payments made in respect of group relief); or