Explanatory Notes

Finance Act 2015

2015 CHAPTER 11

26 March 2015

Introduction

Section 112: Treatment of a Person Who is a Member of a Partnership

Summary

1.This section applies where a person is a member of a partnership.

Details of the Section

2.Subsections (1) and (2) provide that, where a person is a member of a partnership, references to the expenses, income or revenue, or a reduction in income, of the person includes references to the person’s share of the expenses, income or revenue, or a reduction in the income, of the partnership.

3.Subsection (3) defines what is meant by “the person’s share”.

Background Note

4.The diverted profits tax is a new charge on diverted profits. The main objective is to counteract contrived arrangements used by large groups (typically multinational enterprises) that result in the erosion of the UK tax base.