Updates: Partnership Manual
2025
Reference to PM313450 corrected to PM131450
Examples in PM259200 numbered 1 & 2.
Example 2 in PM259200 amended to reflect that in applying the TAAR (ITTOIA/S863G), HMRC will take into account the policy intent of ITTOIA/S863A.
Anti-avoidance: genuine finance
Amendments made to PM259310 to make clear that HMRC accept that an arrangement which results in a genuine contribution made by the individual to the LLP, intended to be enduring and giving rise to real risk will not trigger the TAAR (ITTOIA/S863G).
2024
Partnerships - death or retirement of a partner
Archiving duplicate page.
Page removed. Page not populated.
No changes made as republished page to prompt change notes update
Example added to show how the legislation applies to arrangements where members alter their capital contributions in order to ensure they don't meet Condition C.
Anti-avoidance: genuine finance
Edited PM259310. Change clarifies that even if an arrangement results in a genuine contribution by the individual to the LLP if there is a main purpose of securing the salaried members rules do not apply then the TAAR can still be triggered.
2022
Section added to direct readers to relevant information.
2021
Individual, company and non-resident members
Grammatical correction.
Examples of partnership computations with indirect partners
Names changed.
Link updated.
This page contained an incorrect link. The previous guidance referred readers to PM131450 for information on bodies formed outside of the UK called Limited Liability Partnerships. This has been changed to PM131540.
UK registered partnership with no UK source income or gain
Update to address
2020
Added tab
Disputes over allocation of profits and losses to partners
Updated guidance to include further information to support partners with the details of the dispute process.
Functions of financial businesses regulated by Financial Conduct Authority (FCA)
Changes to guidance made to reflect the new FCA鈥檚 Approved Persons regime, and explain how this interacts with Condition B of the Salaried Member Rules.
2019
Self assessment for partnerships: contents
Added extra link
Template for partners without a UTR
Formatted template
Partnerships that include partnerships as partners
Format changes.
Added content for the FA18 simplifications.
Linking partners to the partnership
Change in guidance due to FA18 simplifications.
Link changed too.
Individual, company and non-resident members
Format text and edit.
Overseas partners in investment partnerships
Page archived.
Archive due to duplication of content.
Tax transparency 鈥榮witched off鈥�
Page republished
format edit.
Link added to PAYE manual.
Format changes.
Format change
LLP: restriction of relief for LLP members
format changes
Format change
Duplication in Gov.uk not internal manual. Unsure why.
link broken
Private Fund limited partnerships
added content
Allocation examples of profits and losses
Reformatted tables
Examples of partnership computations
Reformatted tables
Pseudo share schemes/membership benefit schemes
Content change as incorrect content.
Incorrect content.
Calculating the taxable profits: introduction
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Calculating the taxable profits: steps for computing partnership trading profits
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Calculating the taxable profits: accounting profits
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Calculating the taxable profits: general tax rules
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Calculating the taxable profits: interest paid by the partnership
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Calculating the taxable profits: rent
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Calculating the taxable profits: service companies
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Calculating the taxable profits: partner recruitment costs
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Calculating the taxable profits: partner training costs
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Calculating the taxable profits: termination payments
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Calculating the taxable profits: Partnership annuities: contents
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Calculating the taxable profits: Partnership annuities: the partnership
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Calculating the taxable profits: Partnership annuities: current partners
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Calculating the taxable profits: Partnership annuities: retired partners
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Calculating the taxable profits: costs connected with the capital structure of a business
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Calculating the taxable profits: partner expenses
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Calculating the taxable profits: Directors鈥� fees received by professional partnerships
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Calculating the taxable profits: claims and elections
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Calculating the taxable profits: allocating the taxable profits or allowable losses to partners
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Calculating the taxable profits: Capital Allowances: contents
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Calculating the taxable profits: Capital Allowances: partnership changes
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Calculating the taxable profits: Capital Allowances: connected persons
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Calculating the taxable profits: Capital Allowances: the Annual Investment Allowance (AIA)
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Calculating the taxable profits: Capital Allowances: leasing
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Mixed member partnerships and international aspects: companies in partnership: common issues
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Limited partnerships and limited liability partnerships: limited partnerships - overview
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Limited partnerships and limited liability partnerships: LLPs: overview
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Limited Liability Partnerships: statutory provisions for tax transparency: contents
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Limited partnerships and limited liability partnerships: liquidations
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Limited Partnerships and Limited Liability Partnerships - conversions: contents
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Limited partnerships and limited liability partnerships: restrictions on loss relief for LLP members
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Limited partnerships and limited liability partnerships: nominee members
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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: contents
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Indirect, capital and transfer taxes and other tax obligations: Capital gains: contents
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Indirect, capital and transfer taxes and other tax obligations: Capital gains - introduction
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Indirect, capital and transfer taxes and other tax obligations: Capital gains: Goodwill
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Indirect, capital and transfer taxes and other tax obligations: Capital gains: CG Reliefs
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Indirect, capital and transfer taxes and other tax obligations: Stamp Duty Land Tax (SDLT): contents
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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT) contents
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Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: PAYE
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Indirect, capital and transfer taxes and other tax obligations: Construction Industry Scheme (CIS)
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Indirect, capital and transfer taxes and other tax obligations: deduction of Income Tax at source
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Introduction to Partnerships and Partnership Taxation: contents
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Introduction to Partnerships and Partnership Taxation: what is a partnership?
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Introduction to Partnerships and Partnership Taxation: does a partnership exist?
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Introduction to Partnerships and Partnership Taxation: when does a partnership commence?
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Introduction to Partnerships and Partnership Taxation: who can be a partner?
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Introduction to Partnerships and Partnership Taxation: overview of types of partnership
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Introduction to Partnerships and Partnership Taxation: profit sharing arrangements
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Introduction to Partnerships and Partnership Taxation: overview of how partnerships are taxed
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Trading profits: notional trade and basis periods
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Trading profits: notional trade and basis periods - sole trader and partnership changes
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Trading profits: partnership mergers and demergers
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Trading profits: accounting date changes
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Introduction to Partnerships and Partnership Taxation: non trading income (鈥榦ther income鈥�)
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Self Assessment for partnerships: legal framework
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Self Assessment for partnerships: registration of partnerships with HMRC
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Self Assessment for Partnerships: the nominated/representative partner
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Self Assessment for partnerships: linking partners to the partnership
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Self Assessment for partnerships: the partnership return: contents
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Self Assessment for partnerships: the partnership return: requirements
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Self Assessment for partnerships: the partnership return: operational guidance
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Self Assessment for partnerships: partners鈥� returns: contents
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Self Assessment for Partnerships: partners鈥� returns: returning the partnership profit share
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Self Assessment for partnerships: filing date for partnership return
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Self Assessment for Partnerships: Late filing penalties
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Self Assessment for partnerships: compliance checks: contents
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Self Assessment for partnerships: compliance checks: introduction
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Self Assessment for partnerships: compliance checks: review and liaison
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Self Assessment for partnerships: compliance checks: opening a compliance check
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Self Assessment for partnerships: compliance checks: information powers
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Self Assessment for partnerships: compliance checks: settling partnership enquiries
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Calculating the taxable profits: contents
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Calculating the taxable profits: overriding principle on payments to partners
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Mixed member partnerships and international aspects: companies in partnership: contents
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Mixed member partnerships: company partners
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Mixed member partnerships and international aspects: Residence and the tax consequences: contents
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Mixed member partnerships and international aspects: certificates of residence
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Mixed member partnerships and international aspects: management and control
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Mixed member partnerships and international aspects: where are the profits earned?
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Mixed member partnerships and international aspects: Investment partnerships
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Mixed member partnerships and international aspects: UK registered partnerships with no UK source
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Mixed member partnerships and international aspects: tax status of overseas partnerships
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Mixed member partnerships and international aspects: UK branches of overseas partnerships
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Mixed member partnerships and international aspects: Double Taxation
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Mixed member partnerships and international aspects: Hybrid entities and tax arbitrage
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Limited partnerships and limited liability partnerships: contents
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Limited partnerships and limited liability partnerships: introduction
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Indirect, capital and transfer taxes and other tax obligations: contents
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Limited partnership: restriction of relief for limited partners
Updated links
Venture Capital/Private Equity and the BVCA agreement
Links updated
Link updated
Limited liability partnerships: contents
PM131480 added to menu
Link updated
Links updated
Links updated and formatting
Links updated
Links updated
Tax transparency 鈥榮witched on鈥�
Link updated
LLP: restriction of relief for LLP members
Links updated
LLP: partners' basis periods, losses and overlap relief
Links updated
Links updated
Links updated
Relations that do not constitute a partnership
Links updated
Links updated
Link updated
Husbands, wives, civil partners and minors
Links updated
Link updated
Link updated
Partnerships: mergers and demergers: contents
Review date set
Mergers and demergers: overview
Links updated
Mergers: cessation of previous business and commencement of new business
Links updated
Mergers and demergers: text of Statement of Practice SP 9/86
Link updated
Format and link updated
Link updated
Registration of partners with HMRC
Links updated
The nominated/representative partner
Link pdated
Composite returns for individual non-resident partners
Link change
Link updated
Link updated
Links updated
Calculation of limit relief: partners' capital contribution
Links updated
Links updated
Non-active partners: unrelieved amounts
Links updated
The appropriate notional consideration for services
Link updated
Businesses transferred to the partnership: Examples
Link updated
Links updated
Mixed member partnerships and international aspects: tax status of overseas partnerships
Format fix
Limited liability partnerships: contents
Link added
The nominated/representative partner
Contents added
Claims and elections: contents
Added contents
Self Assessment for partnerships: contents
Page archived 鈥� page replaced under new structure
Companies in partnership: contents
Added contents
Link added.
Partnerships: mergers and demergers: contents
Added further links.
Content updated.
Taxing the profits of a business carried on in partnership
Links added.
Links added.
voluntary returns
Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: PAYE
Page archived 鈥� page replaced under new structure
LINKS ADDED
LINKS ADDED
links added
Limited partnership: restriction of relief for limited partners
Links added
Venture Capital/Private Equity and the BVCA agreement
Links added
Links added
Links Added
Links added
Links added
Links added
Links added and format changed
Link added
Links Added
LLP: restriction of relief for LLP members
Links added.
LLP: partners' basis periods, losses and overlap relief
Links added
Links added
Relations that do not constitute a partnership
Links added
Links added
Links added
Husbands, wives, civil partners and minors
Link added
Link added
Link added
Mergers and demergers: overview
Links added
Mergers: cessation of previous business and commencement of new business
Links added
Overriding principle on payments to partners
hyperlink
Non-active partners: unrelieved amounts
Links added.
The appropriate notional consideration for services
Links added.
Businesses transferred to the partnership: Examples
Link added.
Links added.