145R3. Where a taxpayer is a member of a partnership in a fiscal period of the partnership that ends in a taxation year of the taxpayer, the taxpayer’s share of the partnership’s adjusted resource profits for the year is equal to(a) zero, where the fiscal period of the partnership began before 21 December 1991; and
(b) in any other case, the amount, which may be positive or negative, that could, but for this section, reasonably be considered to represent the taxpayer’s share of the partnership’s adjusted resource profits for the fiscal period, each partnership being, in that respect, deemed to be a taxpayer the fiscal period of which is a taxation year.