1U.K.In ITTOIA 2005, after section 848 insert—
“848ABare trusts
(1)This section applies if—
(a)a partner in a firm is partner as trustee for a beneficiary who is absolutely entitled to the partner's share of the profits of the firm, and
(b)the beneficiary is chargeable to tax on those profits.
(2)References in this Part to a partner or member of the firm include references to the beneficiary.”