This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Business Income Manual

Business Income Manual: Computing the amount to assess: Mixed Membership Partnerships: Excess profit allocation: Appropriate notional profit

ITTOIA/S850C (3)(a)

For the legislation to apply, the profit share of the non-individual member has to exceed the appropriate notional profit.

The appropriate notional profit is made up of two elements:

  • the appropriate notional return on capital (see BIM82750); and
  • the appropriate notional consideration for services (see BIM82760).