Part 2 Multinational Top-up Tax

Part 2 Multinational Top-up Tax

Partnerships

2

(1)     In section 122 (chargeable persons)—

(a)     in subsection (1)(a)(ii), omit “that is not a body corporateâ€,

(b)     in subsection (2)(c)(ii), omit “that is not a body corporateâ€, and

(c)     omit subsections (4) to (6).

(2)     After section 232, insert—

“232´¡Ìý±Ê²¹°ù³Ù²Ô±ð°ù²õ³ó¾±±è²õ

(1)     A partnership is to be regarded for the purposes of this Part as continuing to be the same partnership regardless of a change in membership, provided that a person who was a member before the change remains a member after the change.

(2)     Where—

(a)     ownership interests in a partnership are transferred to more than one individual or entity, and

(b)     the result is a partnership of which none of the original partners are members,

that new partnership is to be treated as if it were the same partnership as the old partnership.

(3)     Where a partnership is otherwise dissolved in an accounting period—

(a)     the partnership is to be treated as a continuing entity for the purpose of dealing with its rights and obligations under this Part in respect of that accounting period and previous accounting periods, and

(b)     for the purposes of Schedule 14

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