Corporation Tax Act 2010 section 958

Application

Section 958 sets out when the restrictions on the use of corporation tax relief within partnerships apply.

• The rules apply where a firm carries on a trade and one of the partners is a company.
• The company partner is referred to throughout this chapter as "the partner company".
• The restrictions only bite where specific arrangements (as defined in section 959) are in place.
• When all three conditions are met, section 960 restricts the corporation tax relief the partner company can use.