Corporation Tax Act 2009 section 619

Partnerships involving companies

Section 619 establishes how derivative contracts held by partnerships that include company partners are taxed, by requiring each company partner to account for credits and debits individually rather than through the partnership's profit calculation.

• The section applies where a firm carries on a trade or business, at least one partner is a company, and the firm holds a contract that is (or would be, if the firm were a company) a derivative contract.
• Credits and debits on the derivative contract must not be included in the firm's overall profit and loss calculation for corporation tax purposes.
• Instead, each company partner must separately bring into account its own credits and debits in respect of the derivative contract for each accounting period in which the conditions are met.
• Specific rules for determining the amounts each company partner recognises, including where fair value accounting is used, are set out in sections 620 and 621.