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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: structured finance: partnership borrowers

When a partnership is the borrower in a simple case

The borrower may be a company or an individual. Alternatively the borrower may be a partnership that holds an income producing asset that it transfers by way of the security for the (in substance) loan. It may be that the asset transferred by way of security is held by a partnership and that it is the partnership itself that is the borrower.

Section 758(4) makes it clear that where the borrower is a partnership then the accounts to consider in order to determine whether the accounts record a financial liability in accordance with GAAP include the accounts of any member of the partnership as well as those of the partnership itself.