Corporation Tax Act 2009 section 1258

Assessment of firms

Section 1258 establishes that a partnership (firm) is not treated as a separate entity from its partners for corporation tax purposes.

• For corporation tax, a firm is not regarded as an entity separate and distinct from its partners, unless specifically stated otherwise
• This applies to all types of business carried on by firms, not just trades
• The rule ensures consistent treatment across all UK jurisdictions, including Scotland where partnerships have separate legal personality under general law
• The treatment mirrors the equivalent income tax rule, keeping the two tax codes aligned