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Contents

Official guidance
International Manual

INTM610000 · Contents: Profit Fragmentation Rules

  • INTM610010 · Introduction
  • INTM610020 · Introduction: Who do these rules apply to? / How will these rules be used?
  • INTM610030 · Introduction: When do these rules apply?
  • INTM610040 · Parties
  • INTM610050 · Parties (Continued)
  • INTM610060 · Profit Fragmentation Arrangements
  • INTM610070 · Profit Fragmentation Arrangements: The Material Provision
  • INTM610080 · Profit Fragmentation Arrangements: Transfer of Value
  • INTM610090 · Profit Fragmentation Arrangements: Tracing Value
  • INTM610100 · Profit Fragmentation Arrangements: Arm’s Length Transfer
  • INTM610110 · Enjoyment Conditions
  • INTM610120 · Enjoyment Conditions: Enjoyment Test
  • INTM610130 · Enjoyment Conditions: Procurer Test
  • INTM610140 · Exception Conditions
  • INTM610150 · Exception Conditions: Tax Mismatch
  • INTM610160 · Exception Conditions: Tax Mismatch: Quantifying the Resident Party’s Tax Reduction
  • INTM610170 · Exception Conditions: Tax Mismatch: Qualifying Deduction and Qualifying Loss Relief
  • INTM610180 · Exception Conditions: Tax Mismatch: Hybrid and Transparent Entities/ Reasonable to Conclude/ UK Resident Non-Domiciled Individuals
  • INTM610190 · Exception Conditions: Tax Advantage Test
  • INTM610200 · Profit Fragmentation Adjustments
  • INTM610210 · Profit Fragmentation Adjustments: Hierarchy of Legislation
  • INTM610220 · Profit Fragmentation Adjustments: NICs Consequences for Individuals
  • INTM610230 · Profit Fragmentation Adjustments: Reimbursement Payments
  • INTM610240 · Double Taxation
  • INTM610250 · Interaction with Other Legislation: Income Chargeable to S720 or S727 ITA 2007
  • INTM610260 · Interaction with Other Legislation: Income Chargeable to S731 ITA 2007
  • INTM610270 · Interaction with Other Legislation: Carried Interest and Disguised Investment Management Fees
  • INTM610280 · Making Adjustment on the Tax Return: Individuals
  • INTM610290 · Making Adjustments on the Tax Return: Members of a partnership required to make adjustments under the Profit Fragmentation legislation
  • INTM610300 · Making Adjustments on the Tax Return: Companies required to make adjustments under the Profit Fragmentation legislation
  1. Contents: Profit Fragmentation Rules
  2. Making Adjustments on the Tax Return: Members of a partnership required to make adjustments under the Profit Fragmentation legislation

INTM610290 | Making Adjustments on the Tax Return: Members of a partnership required to make adjustments under the Profit Fragmentation legislation

From HM Revenue & Customs · International Manual

Adjustments required on the Partnership Return (SA800)

If paragraph 7 of the Profit Fragmentation legislation requires adjustments relating to the income or expenses of a member of a partnership, adjustments must be first be made on the Partnership Return (form SA800).

  • If the required adjustment consists of reducing an expense, disallow the relevant expense that was previously included in the return by making the appropriate entry in one of boxes 3.30-3.45.

  • If the required adjustment consist of an increase in income, increase the income figure by inserting the additional income figure in box 3.67.

  • The adjustments will be carried through to that member’s allocation of profits and losses shown on the partnership statements prepared by the partnership as part of the partnership return.

Adjustments required by partners

The relevant partnership members must reflect the adjustments to the profit/loss shown on the partnership statement in their own returns. Therefore for partnership members who are individuals, the figure at box 8 (on form SA104F and SA104S) must be adjusted to reflect the change to their share of the partnership profit or loss as a result of the adjustments required under paragraph 7 of the Profit Fragmentation legislation. Corporate partners must make the necessary adjustment in their CT computation.

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