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Taxation (International and Other Provisions) Act 2010

Section 681DJ: Apportionment of payments made and of sums obtained

1092.This section provides for apportionments to be made of payments made and sums obtained. It is based on section 783(6) to (8) of ICTA.

1093.Subsection (3) requires apportionments to be not only just but also reasonable. This is a minor change in the law. See Change 5 in Annex 1.

1094.Although section 783(6) and (8) of ICTA refer to vocations carried on in partnership (as well as to trades and professions carried on in partnership), it is considered that vocations cannot be carried on in partnership: see, for example, Change 4 in Annex 1 to the explanatory notes on CTA 2010. Accordingly, subsections (2), (4) and (5) do not refer to vocations.

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Explanatory Notes

Text created by the government department responsible for the subject matter of the Act to explain what the Act sets out to achieve and to make the Act accessible to readers who are not legally qualified. Explanatory Notes were introduced in 1999 and accompany all Public Acts except Appropriation, Consolidated Fund, Finance and Consolidation Acts.

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