CTM01120 | Corporation Tax: introduction: profits from trusts and partnerships
From HM Revenue & Customs · Company Taxation Manual
and S7, formerly ICTA88/S8 (2)
A company is chargeable on any profits:
accruing for its benefit under any trust, or
arising under any partnership
where it would be chargeable on such profits if they accrued to it directly. But it is not chargeable on profits accruing to it in a fiduciary or representative capacity, except, and to the extent of, its own beneficial interest in such profits. Profits arising in the winding-up of a company (see onwards) are chargeable.