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HMRC internal manual

Inheritance Tax Manual

What is a partnership: Cases where there are no deeds

Where there are no Articles, it will usually be clear from the accounts that a partnership exists, i.e. there will be separate Capital Accounts shown for each partner.  Should there be any doubt as to whether or not a partnership exists, consult the Income tax office to see if the existence of the partnership has been accepted for Income Tax purposes. If so, follow their line.

You should also consider whether there was a gift of capital on the commencement of the partnership, or any transfers of value made in connection with changes in the profit sharing ratios. Any cases of difficulty should be referred to Technical for advice.