CG27220 - Partnerships: Calculating a fractional interest in a partnership asset

CG27150 explains that partners are treated as owning fractional interests in each of the assets of the partnership and that a disposal occurs when a partner’s fractional interest in an asset is reduced. This may occur on the disposal of an asset by the partnership or on a change in the partners’ sharing ratios.

A partner’s fractional interest in a partnership asset should be determined by reference to:

• any specific agreement which sets out how capital assets are to be allocated, or if there is no such agreement,
• any agreement or other evidence which sets out how capital profits are to be shared, or if there is no such agreement or evidence,
• any agreement or other evidence which sets out how income profits are to be shared, or if there is no such agreement or evidence,
• Section 24 (1) Partnership Act 1890, which provides that assets should be treated as held by the partners in equal proportions, see BIM82055.