I think my interpretation of "a payment made by a firm" would be the partnership paying the individual rent, for example for using personally owned property (so the equivalent of the S783BP provision for companies and effectively removing the potential for every member of a partnership to get £1,000 tax-free by renting the partnership something).
I have, and I think it’s the gist of one of the legislation sections we read differently.
I read ‘payment by’ as receiving rental income from the partnership (i.e. renting a building to the partnership) rather than receiving a share of partnership rental profits, but I can understand why you’d read it the other way too.
The example in PIM4486 seems to support my reading if you try to interpret what it is trying to show, although I appreciate HMRC examples aren’t often the full picture.
My answers
I think my interpretation of "a payment made by a firm" would be the partnership paying the individual rent, for example for using personally owned property (so the equivalent of the S783BP provision for companies and effectively removing the potential for every member of a partnership to get £1,000 tax-free by renting the partnership something).
Widely drawn legislation is a pain!
Thanks!
It's a shame tax is never set out clearly!
I have, and I think it’s the gist of one of the legislation sections we read differently.
I read ‘payment by’ as receiving rental income from the partnership (i.e. renting a building to the partnership) rather than receiving a share of partnership rental profits, but I can understand why you’d read it the other way too.
The example in PIM4486 seems to support my reading if you try to interpret what it is trying to show, although I appreciate HMRC examples aren’t often the full picture.