64. Partnerships or unincorporated associations
-
(1) Where —
-
(a) a partnership, or unincorporated association or body is dissolved in consequence of —
-
(i) the retirement or withdrawal of one or more, but not all, of its partners or members, or
-
(ii) the admission of a new partner or member;
-
(b) a new partnership, or unincorporated association or body comes into existence consisting of the remaining members and one or more new members; and
-
(c) the new entity continues to carry on the taxable activity of the dissolved entity as a going concern,
the dissolved entity and the new entity are, for the purposes of this Act, deemed to be one and the same, unless the Comptroller, having regard to the circumstances of the case, otherwise directs.
-
(2) In this section —
“dissolved entity” means a partnership or unicorporated association or body that is dissolved;
“new entity” means a new partnership or unincorporated association or body that comes into existence.