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Contents

Official guidance
Corporate Finance Manual

CFM36000 · Loan relationships: partnerships

  • CFM36010 · Overview
  • CFM36020 · Credits and debits calculated separately for each partner
  • CFM36030 · Computing the gross credits and debits
  • CFM36040 · Allocating credits and debits to the company partner
  • CFM36050 · Loans between partners and partnership
  • CFM36060 · Connected company partners
  • CFM36070 · Connected company partners: tax consequences
  • CFM36080 · Company partners and connected debtors
  • CFM36090 · Company partners and connected debtors: definition of ‘connection’ and ‘major interest’
  • CFM36100 · Allocating credits and debits to the company partner: Tax Bulletin article TB62/02
  1. Loan relationships: partnerships: contents
  2. Loan relationships: partnerships: credits and debits calculated separately for each partner

CFM36020 | Loan relationships: partnerships: credits and debits calculated separately for each partner

From HM Revenue & Customs · Corporate Finance Manual

Applying the loan relationships rules

CTA09/PT5/CH9 applies where the following conditions, in S380, are satisfied.

  • A trade, profession or business is carried on by persons in partnership (‘the firm’),

  • any of those persons is a company (a ‘company partner’), and

  • a money debt is owed by or to the firm.

‘Money debt’ is defined at CTA09/S301 - see CFM31020.

Computing the profits

When computing the partnership profits in accordance with CTA09/PT17, S380 excludes any debits or credits from

  • the money debt, or

  • any loan relationship that would be treated as arising from that money debt (such as interest on trade debts).

The debits and credits are instead computed separately for each company partner, by

  • calculating the gross debits and credits (CFM36030), then

  • apportioning them between each partner (CFM36040).

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