Policy paper

Statement of Practice 1 (1979): partnerships

Published 12 January 1979

Paragraph 8 of Statement of Practice D12 explains the circumstances in which the capitalised value of an annuity paid by a partnership to a retired partner will not be treated as consideration for the disposal of his share in the partnership assets. The Commissioners for HM Revenue and Customs have now agreed that this practice will be extended to certain cases in which a lump sum is paid in addition to an annuity. Where the aggregate of the annuity and one-ninth of the lump sum does not exceed the appropriate fraction (as indicated in the Statement) of the retired partner’s average share of the profits, the capitalised value of the annuity will not be treated as consideration in the hands of the retired partner. The lump sum, however, will continue to be so treated.

This extension of the practice will be applied to all cases in which the liability has not been finally determined at the date of this Notice. See also Statement of Practice 1/89.

Statement of Practice D12

Capital gains tax partnerships.

Statement of Practice 1/89

Further extension of Statement of Practice D12