Income Tax Act 2007 Schedule 2 paragraph 8

Partnerships involving companies

Schedule 2 paragraph 8 explains how references to persons and companies in the Act should be read when a partnership includes a mix of companies subject to corporation tax and other partners who are not companies.

• Where a person acts in partnership and at least one partner is a company chargeable to corporation tax, references to "any person" in the Act are read as references to all the partners.
• Where a company acts in partnership and at least one partner is not a company, references to "company" or "person" in provisions amended for corporation tax purposes are read as references to all the partners.
• This interpretive rule applies only so far as is needed to preserve the continuity of the law.
• The provision ensures that mixed partnerships — those containing both corporate and non-corporate members — are treated consistently across income tax and corporation tax legislation.