This type of ‘complex’ arrangement is a variant on the one described at ¶377-040 which uses an existing partnership where the partners are already sharing profits derived from an asset. Either the pension scheme joins the partnership and acquires a share in the profits for a specified period by means of a capital contribution funded by the employer’s pension contribution or an existing partner, which might be the pension scheme or a vehicle which the scheme controls, acquires an increased profit share for that specified period in return for such a capital contribution.

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