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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Schedule 22 Finance Act 2000: Part XIII partnerships - Para 134 transactions not at arm's length


The regulations may provide that for the purposes of paragraphs 58 and 59 (transactions not at arm’s length) the partnership shall be treated-

(a) as an entity separate and distinct from the persons that are its members, and

(b) as if it were a tonnage tax company.


SI00/2303/REG13 transactions between partnership and partner TTM18013
Transfer pricing TTM13300