Corporation Tax Act 2010 section 880

Apportionment of payments made and of sums obtained

Section 880 sets out how payments made by partnerships and sums obtained in respect of asset interests should be apportioned between the relevant parties for the purposes of this chapter.

• Where a partnership makes a payment that qualifies for relevant tax relief, it must be apportioned between the partners on a just and reasonable basis.
• Where a trading partnership obtains a sum in respect of an interest in an asset that continues to be used in the trade, it must be split between partners according to their profit-sharing ratios at the time the sum is obtained.
• Where persons jointly entitled to an interest in an asset obtain a sum in respect of that interest, it must be divided according to their respective rights in the interest.
• The partnership trade rule takes priority over the joint entitlement rule where both could apply.