Corporation Tax Act 2010 section 414

Partnership's income for condition B in section 410

Section 414 sets out how a partnership's income is to be calculated and apportioned when determining whether the leasing income threshold in condition B of the business of leasing plant or machinery test is met.

  • Partnership income is calculated using corporation tax principles for the purposes of the leasing business test.
  • Where income needs to be attributed to the 12-month period ending on the relevant day, it is apportioned on a time basis as the default method.
  • If a time-based apportionment would produce an unjust or unreasonable result for any person, a just and reasonable basis must be used instead.
  • The proportion of income derived from plant or machinery that qualifies under the leasing provisions must always be determined on a just and reasonable basis.

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