Section 1266 — Corporation Tax Act 2009: Resident partners and double taxation agreements

Resident partners and double taxation agreements 1266 1 This section applies if—

a a UK resident company (“the partner”) is a member of a firm which—

i resides outside the United Kingdom, or ii carries on a trade the control and management of which is outside the United Kingdom, and b by virtue of any arrangements having effect under section 2(1) of TIOPA 2010 (“the arrangements”) any of the income of the firm is relieved from corporation tax in the United Kingdom.

2 The partner is liable to corporation tax on the partner's share of the income of the firm despite the arrangements. 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 For the purposes of this section the members of a firm include any company which is entitled to a share of the income of the firm.