In this case, it was said that a partnership deed had been entered into, but it was ruled that in fact no such partnership had existed.
The partnership deed, it was found, was entered into for tax purposes and whilst it was "perfectly good according to its tenor", it had really governed the relationship of the parties, none of its terms or requirements had been put into practice.
It was found that the partnership deed was set on one side and disregarded. As a result, there was no partnership as a matter of fact and so the business could not be dealt with as a partnership for income tax purposes.
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