Partnerships ― overview

Produced by a Tolley Owner-Managed Businesses expert
Owner-Managed Businesses
Guidance

Partnerships ― overview

Produced by a Tolley Owner-Managed Businesses expert
Owner-Managed Businesses
Guidance
imgtext

This guidance note summarises the tax treatment of partnerships, including how taxable profits or losses are calculated and allocated amongst partners with links to more detailed commentary. The guidance note also outlines the different types of partnerships and partners.

The legislation in relation to the treatment of partnerships is at ITTOIA 2005, ss 846–863L (Pt 9) for income tax purposes and CTA 2009, ss 1256–1273A (Pt 17) for corporation tax purposes, and HMRC guidance can be found from PM100000 onwards.

More detailed commentary can be found in Simon’s Taxes B7.101 and Ray: Partnership Taxation, Ch 1 onwards.

Tax treatment of partnerships

All UK partnerships are treated as transparent for tax purposes, including Scottish partnerships despite the fact that Scottish partnerships have a legal personality. This means that one ‘looks through’ the partnership to tax the partners directly. A limited liability partnership (or LLP, see below) is treated as tax transparent as long as it carries on a trade, profession or business with a view to a profit and so would not be tax transparent if, for example, it

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+
  • 13 Nov 2025 12:20

Popular Articles

Relief for employee share schemes

Relief for employee share schemesRemuneration expenses are generally deductible for corporation tax purposes as they are considered to be incurred wholly and exclusively for the purposes of the trade. However, expenses relating to shares are usually classed as capital and are therefore not

14 Jul 2020 13:21 | Produced by Tolley Read more Read more

Enterprise management incentive schemes

Enterprise management incentive schemesWhat is an enterprise management incentive (EMI) scheme?The enterprise management incentive (EMI) scheme is a tax-advantaged share option employee incentive scheme aimed at small entrepreneurial companies that meet certain conditions. It is designed to assist

14 Jul 2020 11:36 | Produced by Tolley Read more Read more

Withholding tax

Withholding taxIntroductionUK tax must be withheld on UK payments including:•interest•royalties•rental incomeUK withholding tax may be reduced under the provisions of a double tax treaty (DTT). Prior to 1 June 2021, payments of interest and royalties made to EU resident associated companies were

14 Jul 2020 14:01 | Produced by Tolley Read more Read more