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Commentary

19.1 The basis for taxing partnership trade profits and losses

BUSINESSES vol 4(2) start-up, sale and purchase
| Commentary

19.1 The basis for taxing partnership trade profits and losses

| Commentary

19 General or limited liability partnership

19.1 The basis for taxing partnership trade profits and losses

The rules relating to taxation of partnership trade profits can be found in the Income Tax (Trading and Other Income) Act 2005 Part 9 (sections 846–863).

The basic rule is that a general partnership is not to be regarded for income tax purposes as an entity separate and distinct from its partners1. Where the partnership is a trading partnership and at least one partner is a resident of the United Kingdom chargeable to income tax, the profits or losses of the trade are calculated as if

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