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HMRC internal manual

Company Taxation Manual

Corporation Tax: introduction: profits from trusts and partnerships

CTA09/S6 and S7, formerly ICTA88/S8 (2)

A company is chargeable on any profits:

  • accruing for its benefit under any trust, or
  • arising under any partnership

where it would be chargeable on such profits if they accrued to it directly. But it is not chargeable on profits accruing to it in a fiduciary or representative capacity, except, and to the extent of, its own beneficial interest in such profits. Profits arising in the winding-up of a company (see CTM36100 onwards) are chargeable.