BIM42125 - Measuring the profits (specific rules & practices) - receipts & deductions: deductions - scope of: partnerships

Partner’s personal or domestic expenses

Payments made by a partnership towards the personal or domestic expenses of a partner are disallowable on dual-purpose grounds. In MacKinlay v Arthur Young McClelland Moores and Co, (see BIM38120), payments made by a partnership towards the removal expenses of partners were held to have an inherently private purpose, despite the advantages to the partnership of the partners' change of residence. But that decision does not preclude a deduction for payments by a partnership to a partner where the sole purpose is a business purpose and the payment is in return for full commercial consideration, such as market value rental for use of a business property (Heastie v Veitch and Co 18TC318 - see BIM38110).