Mitch, not sure that the SLP will be 100 given that in each case the other partner will not be an individual so if SLP is less than 75 which is quite possible there won’t be a para 24 issue. But to answer your question, in principle as soon as you have a partner who is not a body corporate then you are out of para 24. However although I think there is a reasonable argument for a literal approach here, care should be taken to ensure that the additional partner is a genuine partner with substance and not in reality a mere nominee or puppet.