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,

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

Taxation of dividend income

Taxation of dividend incomeIntroductionA dividend is a distribution of profit by a company to its shareholders.A dividend is not only a payment in cash. It can be the issue of new shares in exchange for forfeiting the right to a cash payment (a stock dividend). For more detail, see the Cash

14 Jul 2020 13:48 | Produced by Tolley Read more Read more

Short-term business visitors (STBVs)

Short-term business visitors (STBVs)What is a short-term business visitor?An STBV for UK tax purposes is an individual who performs duties for a non-UK employer and as a part of those duties has been asked to spend a short period working in the UK. There is a common misconception that there is

Read more Read more

Computation of corporation tax

Computation of corporation taxCompanies pay corporation tax on the taxable total profits (TTP) generated in a chargeable accounting period (CAP).To ascertain whether the entity is within the charge to corporation tax, see the Charge to corporation tax guidance note.For more information on the type

14 Jul 2020 11:16 | Produced by Tolley Read more Read more