2024 Partnerships Contributions

Streaming of partnership receipts to partners: An initial contribution

Published Date: 20 Feb 2024


In Australia, the streaming of receipts is income tax driven and is overwhelmingly associated with beneficiaries of discretionary trusts. General law partnerships are still in heavy use in the closely held entity sector. Given this, and that beneficial tax strategies deployed in one entity structure are often desired by the users of other structures, it is appropriate to ask the streaming question in the context of partnerships. The streaming question has a general law dimension and a tax law dimension. This initial contribution is focused on the general law dimension of the question as to whether the streaming of receipts is possible in the partnership context. It attempts to do this by first deriving the principles for streaming, and then applying those principles to the partnership situation. The author’s initial conclusion is that there is good reason why streaming in a partnership is possible under general law, and that this will likely provide the necessary base from which streaming for tax law purposes will be effective.

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2024 Partnerships Contributions

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