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Contents

Official guidance
Partnership Manual

PM213000 · Mixed member rules

  • PM214000 · Overview
  • PM216000 · Who is a non-individual partner
  • PM217000 · When do the rules apply?
  • PM218000 · Condition X
  • PM219000 · Condition Y
  • PM220000 · Appropriate notional profit
  • PM221000 · The appropriate notional return on capital
  • PM222000 · The appropriate notional consideration for services
  • PM223000 · The appropriate notional consideration for services: restriction
  • PM224000 · The power to enjoy
  • PM225000 · Connected parties
  • PM226000 · Arrangements to secure corporation tax rather than income tax treatment
  • PM227000 · Enjoyment Conditions
  • PM228000 · Is the profit share influenced by the power to enjoy?
  • PM229000 · Relevant tax amount
  • PM230000 · Reallocations: Individuals
  • PM231000 · Reallocations: Non-individuals
  • PM232000 · Payments by the non-individual out of its reallocated profit share
  • PM233000 · Interaction with AIFM deferral arrangements
  • PM234000 · Anti-avoidance
  • PM235000 · Other related guidance
  • PM236000 · Businesses transferred to the partnership
  • PM237000 · Businesses transferred to the partnership: Examples
  • PM238000 · Takeover of the LLP
  • PM239000 · Private equity investment
  • PM240000 · Share issues
  • PM241000 · Pseudo share schemes/membership benefit schemes
  • PM242000 · International structures
  • PM243000 · Commencement
  • PM244000 · Excess loss allocation rules
  • PM245000 · When do the restrictions apply?
  • PM246000 · The effect of the restrictions?
  • PM247000 · Transitional provisions
  • PM248000 · Close companies: loans to participators and arrangements conferring benefit on participator
  1. Mixed member rules: contents
  2. Connected parties

PM225000 | Connected parties

From HM Revenue & Customs · Partnership Manual

S850C (18)(a) ITTOIA 2005, S993 ITA 2007

The individual has the power to enjoy the profits of the non-individual partner if they are connected persons within the definition at S993 ITA 2007, other than simply being connected through being partners.

If the parties are only connected by being partners in the partnership, then they are not connected for the purposes of Condition Y.

If they are connected then the individual has the power to enjoy the profit share, and Condition Y is satisfied, see PM219000.

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