This section aims at preventing abuses in partnerships involving companies in the matter of group relief. The section is designed to ensure that relief for losses can only be allowed in respect of a company's share in a partnership profit or loss where the share really accrues to or is borne by the partner company. Where artificial arrangements exist—for example, where one partner pays another for its right to claim tax allowances or receives compensation for meeting actual losses—relief for losses in a partnership trade will be confined within the partnership and will not be available for relief against other profits of a partner which is a company. The examples show some of these devices.
SECTION 122.
Question proposed: " That section 122 stand part of the Bill."
How did these ingenious devices come to the attention of the Department of Finance when there was no group relief? What was the genesis of this ingenuity?
They have been highlighted elsewhere.
Question put and agreed to.