SCHEDULE 7PARTNERSHIPS

PART 5TRANSACTIONS INVOLVING TRANSFERS FROM A PARTNERSHIP

Corresponding partner

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1

For the purposes of paragraph 22 (see Step 2), a person is a corresponding partner in relation to a relevant owner if, immediately before the transaction—

a

the person was a partner, and

b

the person was the relevant owner or was an individual connected with the relevant owner.

2

For the purpose of sub-paragraph (1)(b), a company is to be treated as an individual connected with the relevant owner if it—

a

holds property as trustee, and

b

is connected with the relevant owner only because of section 1122(6) of the Corporation Tax Act 2010 (c. 4) (as it has effect with the omission of subsection (6)(c) to (e)).