CTM36520 | Particular topics: companies in partnership: different classes of partner
From HM Revenue & Customs · Company Taxation Manual
The three-stage approach set out also applies where it is necessary to calculate and apportion profits where different classes of member are to be taxed by reference to different rules.
Example
A UK partnership has two corporate members: Company A - a UK resident, and Company B - non-resident. Profits are shared equally. The partnership’s worldwide profits chargeable as trading income amount to £10,000 of which £7,500 is earned in the UK.
Computation for UK resident member
Step 1 Calculate the profits as if all the members were UK resident companies:
Profit £10,000.
Step 2 Allocate that profit between all the members:
Company A £5,000.
Company B £5,000.
Step 3 Assess Company A on its share of that profit:
£5,000.
Computation for non-resident member
Step 1 Calculate the profits as if all the members were non-resident companies:
Profit £7,500.
Step 2 Allocate that profit between all the members:
Company A £3,750.
Company B £3,750.
Step 3 Assess Company B on its share of that profit:
£3,750.