Three additional modifications are made in working out the net income of a partnership.
- First, the partnership is treated as a resident of the same country as the CFC.
- Secondly, a dividend will not be notional exempt income of a partnership unless the dividend is paid out of previously attributed income.
- Thirdly, the capital gains tax provisions apply to assets acquired by a partnership after 19 September 1985 - the deemed acquisition of assets on 30 June 1990 for CFCs does not apply to assets held by partnerships.