This section applies where the participants in a co-ownership F2... contractual scheme together carry on a qualifying activity.

Each participant in the scheme is for the purposes of this Part to be regarded as carrying on the qualifying activity.

Subsection (2) applies in relation to a participant only to the extent that the profits or gains arising to the participant from the qualifying activity are, or (if there were any) would be, chargeable to tax.

But in determining for the purposes of subsection (1) whether or to what extent the participants in a co-ownership F3... contractual scheme together carry on a qualifying activity, assume that profits or gains arising to all participants from the qualifying activity are, or (if there were any) would be, chargeable to tax.