INTM489685 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: section 86 – application to partnerships

Where the foreign company is a member of a partnership, references in section 86 to a trade being carried on by the company or to a company supplying services, goods or other property include cases where the partnership carries on the trade or makes the supplies. Also, for the purpose of the mismatch condition, any provision made or imposed between the partnership and another person is treated as made or imposed between the company and that other person.