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Contents

Official guidance
Capital Gains Manual

CG27000C · Partnerships

  • CG27000 · Contents: Statutory rules, Statements of Practice and SA Returns
  • CG27020 · Partnerships, limited partnerships and limited liability partnerships
  • CG27050 · Limited liability partnerships- statutory rules
  • CG27070 · Limited Liability partnerships: transfer of a partnership business to a LLP
  • CG27080 · Partnerships, limited partnerships and limited liability partnerships: Limited liability partnerships: roll-over relief and gifts hold-over relief
  • CG27100 · Partners
  • CG27150 · Statement of practice D12: summary
  • CG27170 · Statement of practice D12: full text
  • CG27200 · Partnership assets
  • CG27220 · Calculating a fractional interest in a partnership asset
  • CG27250 · Valuation of a partner's fractional interest in a partnership asset: SP D12:
  • CG27300 · Fractional interests in partnership assets acquired in stage: SPD12.
  • CG27350 · Disposals of partnership assets: SP D12
  • CG27400 · Partnership assets divided in kind among the partners: SP D12
  • CG27500 · Changes in fractional interests in partnership assets: SP D12: Sections 4, 6 and 7
  • CG27540 · Changes in fractional interests in partnership assets: examples
  • CG27640 · Partners joining or leaving a partnership: examples
  • CG27700 · Partnership mergers: SP D12: Section 10
  • CG27800 · Transfers not at arm’s length and connected persons rules: SP D12: Section 8
  • CG27900 · Transfer of an asset to a partnership: SP D12: Section 5
  • CG27940 · Example 1: transfer of an asset at market value
  • CG28000 · Partnership goodwill and negligible value claims
  • CG28100 · Rebasing of interests in partnership assets held at 31 March 1982
  • CG28140 · Rebasing: changes in partnership sharing ratios: SP1/89
  • CG28230 · Rebasing: examples: FA 2008 rules: change in partnership sharing ratios on or after 6 April 2008 - FA 2008 rebasing rules
  • CG28290 · Rebasing: deferred gains: SP1/89
  • CG28300 · Indexation allowance
  • CG28400 · Partnership annuities: SP D12
  • CG28500 · Transfer of a partnership business and capital gains reliefs: entrepreneurs’ relief, “roll-over” relief and gift “holdover” relief: SP D12: Section 14
  1. Partnerships: contents
  2. Partnerships: Calculating a fractional interest in a partnership asset

CG27220 | Partnerships: Calculating a fractional interest in a partnership asset

From HM Revenue & Customs · Capital Gains Manual

CG27150 explains that partners are treated as owning fractional interests in each of the assets of the partnership and that a disposal occurs when a partner's fractional interest in an asset is reduced. This may occur on the disposal of an asset by the partnership or on a change in the partners' sharing ratios.

A partner's fractional interest in a partnership asset should be determined by reference to:

  • any specific agreement which sets out how capital assets are to be allocated, or if there is no such agreement,

  • any agreement or other evidence which sets out how capital profits are to be shared, or if there is no such agreement or evidence,

  • any agreement or other evidence which sets out how income profits are to be shared, or if there is no such agreement or evidence,

  • Section 24 (1) Partnership Act 1890, which provides that assets should be treated as held by the partners in equal proportions, see BIM82055.

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