BLM81025 - Sale of lessor companies and similar arrangements: partnerships: identifying a ‘qualifying change�
Section 415 CTA2010
In most circumstances it will be easy to see when there is a qualifying change in a partner’s share in the profits or losses of the business.
»Ê¹ÚÌåÓýapp relevant percentage share is the percentage share in the profits or losses of the business for tax purposes. Typically the allocation of profits or losses will be on a simple percentage basis so that a partner will be entitled to, say, 50% of all profits or losses. If a partner entitled to 50% of the profits or losses agrees to take only a 10% share there will be a fall of 40% ,this is a qualifying change. If a partner entitled to 50% of the profits or losses decides to leave the partnership then there will be a fall of 50%, this is a qualifying change.