SCHEDULE 17Partnerships

PART 4Transactions involving transfer to a partnership

Corresponding partner

16

(1)

For the purposes of paragraph 14 (see Step 2), a person is a corresponding partner in relation to a relevant owner if, immediately after the land transfer—

(a)

the person is a partner, and

(b)

the person is the relevant owner or is an individual connected with the relevant owner.

(2)

For the purposes of sub-paragraph (1)(b) a company is to be treated as an individual connected with the relevant owner in so far as it—

(a)

holds property as trustee, and

(b)

is connected with the relevant owner only because of section 1122(6) of the Corporation Tax Act 2010 (c.4).