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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Financial Institutions: Partnerships


All partnerships, including general partnerships, limited partnerships and limited liability partnerships, are treated as entities by all of the agreements for automatic exchange of information. Therefore, for all purposes of this guidance, a partnership is to be treated as if it were an entity with separate legal personality.

A partnership can be either a Financial Institution or an NFE.  To determine the status of the partnership you should consider whether or not it meets any of the definitions of Financial Institution [see IEIM400600]. If it does not it will be an NFE [see IEIM404040].