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In section 59 of TCGA 1992 (partnerships), insert at the end—
In section 858 of ITTOIA 2005 (resident partners and double taxation agreements), insert at the end—
The amendments made by subsections (1) to (3) are treated as always having had effect.
For the purposes of the predecessor provisions, the members of a partnership are to be treated as having included, at all times to which those provisions applied, a person entitled to a share of income or capital gains of the partnership.
"The predecessor provisions" means—
section 153(4) and (5) of the Income and Corporation Taxes Act 1970 (c. 10) (as it had effect under section 62(2) of F(No.2)A 1987), and
sections 112(4) to (6) and 115(5) of ICTA.