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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Switzerland: Partnerships

The agreement makes it clear that, if a partnership is a resident of Switzerland and is entitled, in accordance with the provisions of the agreement, to exemption from United Kingdom tax on any income, the United Kingdom nevertheless has the right to tax a United Kingdom resident partner on his share of the partnership income. Such income is deemed to be income from a source in Switzerland (Article 27(2)).

The agreement provides in Article 4 (1) that, in the case of Switzerland, the term `resident of a Contracting State’ includes a partnership created or organised under Swiss law. This provision should not be understood to override the general requirement that a resident must be liable to taxation in the relevant Contracting State. Where a claim is received in respect of the income of a Swiss partnership it should be ascertained that the income is actually taxed in Switzerland. Any claim that income of a Swiss partnership which has not been taxed in Switzerland should be relieved from taxation in the United Kingdom should be referred to Business Profits, International.