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HMRC internal manual

Business Leasing Manual

Sale of lessor companies and similar arrangements: partnerships: meaning of ‘qualifying change’ in company’s interest in a business

Section 415 CTA2010

There is a ‘qualifying change’ in a company’s interest in a business on any day when its percentage share in the profits of the partnership business at the end of the day is less than its percentage share at the start of the day.

Any change in partnership sharing arrangements will constitute a qualifying change including a reduction to a nil share so that if a company leaves a partnership or a partnership is dissolved this too will constitute a ‘qualifying change in a company’s interest in a business.