Part 9Partnerships
Firms with a foreign element
857Partners to whom the remittance basis F1applies
(1)
This section applies if—
(a)
a firm carries on a trade wholly or partly outside the United Kingdom,
(b)
the control and management of the trade is outside the United Kingdom, and
F2(c)
section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to a partner for a tax year.
(2)
The partner's share of the profits of the trade arising in the United Kingdom is determined in accordance with sections 849 to F3851.
(3)
The partner's share of the profits of the trade arising outside the United Kingdom is treated as relevant foreign income F4....