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.