BLM81045 | Sale of lessor companies and similar arrangements: partnerships: change in a partner company’s interest in the business - identifying ‘ relevant transferred plant or machinery

Section 410 CTA2010

In a simple case where there is a change in a partner company’s share of the business the rules identify assets transferred from the ‘selling partner’ or partners and any company associated with that partner.

Example: change in interest in business

View diagram for this example

Here B Ltd and G Ltd sell part of their interest in P, the partnership, to I Ltd. B Ltd and G Ltd are therefore the companies that are the ‘selling companies’ the companies ‘in relation to whose interest in the business there is a qualifying change’ and the ‘associated companies’ are traced through these partner companies. The associated companies of the relevant company are therefore the shaded companies.

• B Ltd is the partner company;

• C Ltd, E Ltd and F Ltd are all associated companies of B Ltd;

• G Ltd is the other partner company in relation to whose interest there is a qualifying change; and

• H Ltd is an associated company of G Ltd.