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Taxation (International and Other Provisions) Act 2010

Section 564X: Treatment of principal under profit share agency arrangements

786.This section ensures that in the case of profit sharing arrangements the deposit-taker is taxable in respect of all of the profit resulting from the use of the money – both the depositor’s share of profit made under the arrangements and also the amount that the deposit-taker can retain. It is based on section 49A(3) of FA 2005. The corresponding rule for corporation tax is section 516 of CTA 2009.

787.The deposit-taker is entitled to relief for the depositor’s share of profit.

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