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HMRC internal manual

Business Income Manual

Partnerships: Limited Liability Partnership (LLP): property investment LLP

S1004 Income Tax Act 2007, S1135 Corporation Tax Act 2010

Where a pension fund, the pension business of a life insurance company or the tax exempt business of a friendly society receives income or gains in their capacity as a member of a property investment LLP the normal taxation exemptions in respect of that income or gains are disapplied.

A property investment LLP is a LLP whose business consists wholly or mainly in the making of investments in land and the principal part of whose income is derived from investments in land. Land has the meaning given by the Interpretation Act 1978 so that it includes ‘buildings and structures, land covered with water, and any estate interest, easement, servitude or right in or over land’.