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S852 Income Tax (Trading and Other Income) Act 2005

For the purpose of computing individual partners� Income Tax liabilities the share of trade profits allocated to each partner is treated as having been derived from a separate, ‘notional trade�, which that partner carries on alone.

If the partnership business comprises two or more trades, each partner will also have two or more notional trades.

This guidance at PM163090- PM163140 applies only for the purposes of Income Tax. See CTM36500 onwards for guidance on corporate partners.

Where a partner is an ’indirect partner� (see PM132100) in a partnership or partnerships the share of trade profits allocated to each partner from each partnership are treated as having been derived from a separate, ‘notional trade�, which each partner carries on alone.