731-560 Company in leasing partnership where profit sharing not on ‘allowable basis’
If a company is carrying on a business of leasing plant or machinery in partnership with others, and both its share of profits and its entitlement to capital allowances are determined, in an accounting period, by the same single percentage, there is no restriction of loss relief (CTA 2010, s. 887). Profits for this purpose do not include chargeable gains.
However, unless this condition is met, the following restrictions apply.
If the company's notional business shows a loss for corporation tax purposes, any capital allowance, or part of the total capital allowances, that causes or adds to the loss is restricted (‘the restricted part of the loss’) (CTA 2010, s. 888).