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Corporation Tax Act 2009
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385Company partners' shares where firm owns deeply discounted securities
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(1)This section applies if the firm holds a deeply discounted security.
(2)Each partner is treated for the purposes of this Chapter as beneficially entitled to the share of the security specified in subsection (3).
(3)That share is the share to which the partner would be entitled if—
(a)all the partners were companies, and
(b)the security were apportioned in the shares in which any profit or loss would be apportioned between them in accordance with the firm’s profit-sharing arrangements.
(4)In this section “deeply discounted security” has the same meaning as in Chapter 8 of Part 4 of ITTOIA 2005 (profits from deeply discounted securities) (see section 430 of that Act).
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