INTM489775 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: partnerships

The legislation contains provisions to ensure this Part of the Act applies correctly where a company is a member of a partnership. These provisions ensure that any references to the expenses or income or revenue of the company apply to that person’s share of the income etc. as determined by apportioning the amounts between the partners on a just and reasonable basis. This will normally follow the profit-sharing ratios applicable to the relevant companies. The provisions mean, for example, that rules such as that relating to the sales revenue threshold apply properly to companies that are members of a partnership, by reference to the proportion of the partnership profits allocated to the company.