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HMRC internal manual

Capital Gains Manual

Roll-over relief: Limited Liability Partnerships

A limited liability partnership (LLP) which is carrying on a trade or business with a view to profit is treated for capital gains purposes in the same way as a non-corporate partnership, see CG 27020+. This means that the LLP itself is regarded as transparent for tax purposes so that any dealings in partnership assets are treated as dealings by the members. Roll-over relief is available to the members of a LLP subject to the relevant conditions being met.

When a LLP ceases to trade, see CG27050, the transparency treatment is switched off and the LLP is treated thereafter as a body corporate. In certain circumstances TCGA1992/S156A provides for rolled-over gains to be brought back into charge immediately before the transparency treatment ceases to apply, see CG27080.