»Ê¹ÚÌåÓýapp

S850C(5) ITTOIA 2005 and S1264A CTA 2009

As the individual is being taxed on part of the profit share allocated to the non-individual member, the taxable profit share of the latter has to be reduced, so that the profits are taxed only once.

»Ê¹ÚÌåÓýappre may be differences between the way that the taxable profits are calculated for individual and non-individual members, in particular, due to different computational rules for Income Tax and Corporation Tax.

»Ê¹ÚÌåÓýapprefore, rather than simply reducing the profit share of the non-individual member by the amount by which the individual membersâ€� profit shares are increased, any adjustment should be made on a just and reasonable basis taking into account the facts of that case.