Corporation Tax Act 2009 Explanatory Notes

Section 537: Payments in return for capital contribution to partnership

1438.This section deals with arrangements under which a company obtains a return by acquiring an interest in a firm for an amount which will increase in value in a similar way to interest. It is based on section 91H(1) to (4) of FA 1996.

1439.In accordance with the Partnership Act 1890, in this Act reference to the relationship between the partners is a “partnership”, but the collection of partners is a “firm”.

Back to top