It seems a simple question. For CGT purposes TCGA92/S59 (1)treats partners as persons chargeable to tax on gains arising on disposals of interests in partnership assets rather than the partnership itself..
Does that extend to income tax so that where an LP subscribes for shares in a trading comapny those shares are issued to the partners? The question arises where a loss is claimed under TCGA s24 in relation to those shares by the individual partner. Can he or she also claim relief under ITA 2007 s131-that is to say can the partner claim the shares were issued to him[ITA s135(2)] if the subscription was made by the LP