Where 2 or more persons carry on a trade or business in partnership—
tax in respect of chargeable gains accruing to them on the disposal of any partnership assets shall, in Scotland as well as elsewhere in the United Kingdom, be assessed and charged on them separately, and
any partnership dealings shall be treated as dealings by the partners and not by the firm as such, ...
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Subsection (3) applies if—
a person resident in the United Kingdom ("the resident partner") is a member of a partnership which resides outside the United Kingdom or which carries on any trade, profession or business the control and management of which is situated outside the United Kingdom, and
by virtue of any arrangements that have effect under section 2(1) of TIOPA 2010 ("the arrangements") any of the chargeable gains of the partnership are relieved from capital gains tax or corporation tax in the United Kingdom.
The arrangements (so far as providing for that relief) do not affect any liability to capital gains tax or corporation tax in respect of the resident partner's share of any chargeable gains of the partnership.
For the purposes of subsections (2) and (3) the members of a partnership include any person entitled to a share of chargeable gains of the partnership.