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HMRC internal manual

Corporate Finance Manual

Deemed loan relationships: returns from partnerships: main sections of legislation

Overview of legislation

This guidance applies to companies that have interests in partnerships up to 21 April 2009 

CTA09/S537 deals with ‘relevant arrangements’ under which a company obtains a return by acquiring a partnership interest for an amount equal to its discounted future value. This is intended to deal with Scheme 1 as set out in CFM45420.

CTA09/S538 deals with schemes where companies invest money in the form of capital contributions, initially receiving a share of the partnership profits smaller than would be received by reference to that contribution but with a compensating greater entitlement to capital of that partnership later on. This is intended to deal with Scheme 2 as set out in CFM45420.