Part 9Partnerships

Firms with a foreign element

857Partners to whom the remittance basis may apply

1

This section applies if—

a

a firm carries on a trade wholly or partly outside the United Kingdom,

b

the control and management of the trade is outside the United Kingdom, and

c

a partner who is a UK resident individual—

i

meets condition A or B in section 831 (conditions to be met for income to be charged on the remittance basis), and

ii

makes a claim to that effect for a tax year.

2

The partner’s share of the profits of the trade arising in the United Kingdom is determined in accordance with sections 849 to 856.

3

The partner’s share of the profits of the trade arising outside the United Kingdom is treated as relevant foreign income for the purposes of this Act (see Part 8).