SCHEDULES

SCHEDULE 4Avoidance involving profit fragmentation arrangements

10Treatment of a person who is a member of a partnership

1

This paragraph applies where a person is a member of a partnership.

2

Any references in this Schedule to the expenses, income, profits or losses of, or to the adjustment of the expenses, income, profits or losses of, the person includes a reference to the person’s share of the expenses, income, profits or losses of, or adjustment of the expenses, income, profits or losses of, the partnership.

3

For this purpose “the person’s share” of an amount is determined by apportioning the amount between the members of the partnership on a just and reasonable basis.