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Updates: Partnership Manual

2024

19 September 2024 published amendments

1 August 2024 published amendments

Glossary/style guide of terms

Page removed. Page not populated.

28 February 2024 published amendments

Partnership Manual

No changes made as republished page to prompt change notes update

21 February 2024 published amendments

Becoming a member

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

8 November 2022 published amendments

Mixed member rules: contents

Section added to direct readers to relevant information.

26 May 2022 published amendments

Limited liability partnerships: contents

Links to PM131560 archived.

LLP: Property Investment LLP

Page archived.

2021

22 November 2021 published amendments

10 November 2021 published amendments

9 November 2021 published amendments

LLP: overview

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.

29 March 2021 published amendments

2020

17 November 2020 published amendments

12 November 2020 published amendments

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.

21 May 2020 published amendments

Functions of financial businesses regulated by Financial Conduct Authority (FCA)

Changes to guidance made to reflect the new FCA’s Approved Persons regime, and explain how this interacts with Condition B of the Salaried Member Rules.

2019

20 December 2019 published amendments

18 December 2019 published amendments

Partnerships that include partnerships as partners

Format changes.

Added content for the FA18 simplifications.

17 December 2019 published amendments

Linking partners to the partnership

Change in guidance due to FA18 simplifications.

Link changed too.

30 October 2019 published amendments

Individual, company and non-resident members

Format text and edit.

Overseas partners in investment partnerships

Page archived.

Archive due to duplication of content.

9 October 2019 published amendments

8 October 2019 published amendments

LLP: overview

format edit.

LLP: Compliance

Link added to PAYE manual.

LLP: Computation of profits

Format changes.

LLP: partners interest relief

Format change

LLP: restriction of relief for LLP members

format changes

LLP: International aspects

Format change

3 October 2019 published amendments

LLP: Conversions

Duplication in Gov.uk not internal manual. Unsure why.

Profit sharing arrangements

link broken

15 August 2019 published amendments

5 August 2019 published amendments

26 July 2019 published amendments

Pseudo share schemes/membership benefit schemes

Content change as incorrect content.

International structures

Incorrect content.

4 July 2019 published amendments

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’ 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: claims for Capital Allowances on partnership assets

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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: what is a company partnership?

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Mixed member partnerships and international aspects: companies in partnership: computation and allocation of profits

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Mixed member partnerships and international aspects: companies in partnership: common issues

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Mixed member partnerships and international aspects: companies in partnership: loans to participators

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Mixed member partnerships and international aspects: residence and the tax consequences: UK resident members

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Mixed member partnerships and international aspects: residence and the tax consequences: Non-resident members: individuals

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Mixed member partnerships and international aspects: residence and the tax consequences: Non-resident members: companies

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Mixed member partnerships and international aspects: residence and the tax consequences: Non-resident company members trading in the UK

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Mixed member partnerships and international aspects: Residence and the tax consequences: Non-resident company members not trading in the UK

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Limited partnerships and limited liability partnerships: limited partnerships - overview

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Limited partnerships and limited liability partnerships: limited partnerships - restrictions on loss relief for limited partners

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Limited partnerships and limited liability partnerships: venture capital/private equity and the BVCA agreement

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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 Liability Partnerships: statutory provisions for tax transparency: tax transparency ‘switched on’

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Limited Liability Partnerships: statutory provisions for tax transparency: tax transparency ‘switched off’

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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: conversions - business transferred from general partnership

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Limited Partnerships and Limited Liability Partnerships - conversions: business transferred from company

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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: distinct legal personality and Taxes Management provisions

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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: VAT and partnerships: VAT and partnerships - introduction

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Registration and liability to VAT

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: partner changes

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Group VAT registration and partnerships

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: VAT position of partnership contributions

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: VAT avoidance using partnerships

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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: VAT and partnerships: Stamp Duty Land Tax (SDLT) - introduction

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Stamp Duty Land Tax (SDLT): SDLT & Partnerships: General

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Stamp Duty Land Tax (SDLT): special partnership provisions

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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Stamp Duty Land Tax (SDLT): SDLT avoidance

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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: Inheritance Tax (IHT): Transfers of partnership assets

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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): Valuing the partnership interest

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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): Situs of partnership interest

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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): Business Property Relief

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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): Family Limited Partnerships

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Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: contents

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Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: Introduction

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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: PAYE and National Insurance: National Insurance Contributions (NICs)

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Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: Class 4 NIC relief for partner’s losses

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Indirect, capital and transfer taxes and other tax obligations: PAYE and National Insurance: Employer’s Class 1 NICs

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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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3 July 2019 published amendments

About this manual

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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: relations that do not constitute a partnership

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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: taxing the profits of a business carried on in 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: contents

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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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Trading profits: overlap

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Introduction to Partnerships and Partnership Taxation: non trading income (‘other income’)

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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: Standard Accounts Information (SAI) or full accounts and computations

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Self Assessment for partnerships: the partnership return: operational guidance

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Self Assessment for partnerships: partners’ returns: contents

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Self Assessment for Partnerships: partners’ returns: returning the partnership profit share

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Self Assessment for Partnerships: partners’ returns: composite returns for individual non-UK resident partners

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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: Composite SA returns for non-resident individual members

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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: summary of filing requirements for partnerships with foreign aspects

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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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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Does a partnership exist?

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Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): General transparency principle

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2 July 2019 published amendments

Limited partnership: restriction of relief for limited partners

Updated links

Venture Capital/Private Equity and the BVCA agreement

Links updated

Nominee members

Link updated

Limited liability partnerships: contents

PM131480 added to menu

LLP: overview

Link updated

LLP: Conversions

Links updated

LLP: Taxation

Links updated and formatting

LLP: Compliance

Links updated

LLP: Computation of profits

Links updated

Tax transparency ‘switched on’

Link updated

LLP: restriction of relief for LLP members

Links updated

LLP: partners' basis periods, losses and overlap relief

Links updated

LLP: NIC

Links updated

Scottish partnerships

Links updated

Relations that do not constitute a partnership

Links updated

Partners: overview

Links updated

Types of partner

Link updated

Husbands, wives, civil partners and minors

Links updated

Does a partnership exist?

Link updated

Partnerships - dissolution

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

Profit sharing arrangements

Format and link updated

How partners are taxed

Link updated

Registration of partners with HMRC

Links updated

The nominated/representative partner

Link pdated

Composite returns for individual non-resident partners

Link change

Introduction

Link updated

Review and liaison

Link updated

Opening a compliance check

Links updated

Calculation of limit relief: partners' capital contribution

Links updated

Limited Partners

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

Private equity investment

Links updated

Mixed member partnerships and international aspects: tax status of overseas partnerships

Format fix

1 July 2019 published amendments

28 June 2019 published amendments

26 June 2019 published amendments

19 June 2019 published amendments

2018

22 November 2018 published amendments