BIM72620 - Computing the amount to assess: Partnerships - loss relief restrictions: Limited partners - example

On 6 April 2005 X joins an existing partnership as a limited partner.

Capital introduced

X introduces the following capital into the partnership:

6 April 2005: £90,000.

6 April 2006: £25,000.

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Share of partnership profits and losses

X’s share of the partnership’s trading profits and losses are:

Year ended 5 April 2006: Loss (£140,000).

Year ended 5 April 2007: Profit £60,000.

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Drawings

X takes no drawings from the partnership.

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Capital contributions

X’s capital contributions for the purposes of loss relief restrictions are:

At 5 April 2006: £90,000.

At 5 April 2007: £175,000 (£90,000 + £25,000 + £60,000 undrawn profits).

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Loss relief claims

ICTA88/S117 (now ITA07/S104) restricts relief that may be given against other income to the amount of X’s capital contribution at 5 April 2006 (£90,000). Relief given against other income is restricted to:


Year Relief given under Against other income
2002/03 ICTA88/S381 £90,000

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Losses carried forward

The remaining £50,000 of the £140,000 losses sustained in 2005/06, for which relief cannot be given against X’s other income or gains, can be carried forward under ICTA88/S385 (ITA07/S83 from 6 April 2007) and set against X’s share of the partnership’s trading profits for 2006/07 and later years.