Corporation Tax Act 2009 section 381

Determinations of credits and debits by company partners: general

Section 381 explains how the loan relationship credits and debits of a partnership are allocated to each corporate partner for corporation tax purposes.

• Each corporate partner is treated as if the partnership's money debt were owed by or to that partner directly, for the purposes of its own trade or business.
• Where the debt arises from a lending transaction, each corporate partner is treated as having its own loan relationship in respect of that debt.
• Any actions taken by or in relation to the partnership in connection with the debt are treated as actions of each corporate partner.
• Each corporate partner's credits and debits are its appropriate share of the total, determined by reference to the partnership's profit-sharing arrangements.