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Capital Gains Tax for Partnerships

Is it going to get easier?
John Endacott Tax Partner Winter Rule outlines the basic principles of CGT for partnerships and considers some of the particular planning opportunities presented by the PBR announcements
As readers are well aware traditional partnerships are not separate legal entities under UK law (excluding Scotland) and so when capital gains tax (CGT) was introduced in 1965 it was only felt necessary to legislate a 'look-through' provision which is now contained in TCGA 1992 s 59. Life was never that simple and inevitable complexities followed such that eventually Statement of Practice D12 was introduced in 1975 and this remains the bedrock of the treatment of partnerships for CGT purposes. There have been subsequent revisions to SP D12 with the only legislative change...

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