427. Partnerships.

Unless otherwise indicated (whether expressly or by implication) a firm1 is not regarded for income tax or corporation tax purposes as an entity separate and distinct from the partners2.

Other principal matters in regard to the taxing of partnership income are:

  1.  

    (1)     for any period of account of a trading firm, in relation to any:

    1.  

      (a)     UK resident partner of the firm chargeable to income tax, the profits or losses of the trade are calculated as if the firm were a UK resident individual3; and

    2.  

      (b)     non-UK resident partner of the firm chargeable to income tax, the profits or losses