Corporation Tax Act 2010 section 357WH

Allocation of Northern Ireland profits etc. of firm to company

Section 357WH explains how a company partner's share of a firm's trading profits or losses is split between Northern Ireland and mainstream categories, and how those categories are preserved through the standard partnership allocation rules.

• Where a firm has at least one corporate partner, its trade profits or losses may be Northern Ireland profits or losses, mainstream profits or losses, or a combination of both
• The firm's profit-sharing arrangements are applied separately to the Northern Ireland and mainstream categories when allocating each corporate partner's share
• If the overall partnership rules reduce a company's profit share to nil (because other partners have losses), the company is treated as having no Northern Ireland or mainstream profit or loss
• If the overall partnership rules reduce (but do not eliminate) a company's share, its Northern Ireland and mainstream amounts are each reduced by the same proportion