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HMRC internal manual

Company Taxation Manual

Particular bodies: unincorporated associations: is it a partnership?

In the case of Blackpool Marton Rotary Club v Martin (1988) 62TC686 the club argued that it fell within the definition of a partnership because it was an association of persons ‘carrying on a business in common with a view to profit (the Partnership Act 1890). This was rejected by the appeal commissioners and was confirmed by Hoffmann J.  He contrasted the position of partners, who are individually entitled to some proportion of profits, with the members of the club, who were not individually entitled to share in any profits that might arise from its activities.  Their entitlement was to whatever privileges were conferred upon them by the rules of the club and no more.

There is guidance in BIM82000 onwards on determining whether a partnership exists.