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HMRC internal manual

International Manual

Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax

Treaty law - partnerships - non-resident partners

There is no concept under the UK Taxes Acts of partnership residence but that is not the case under the law of some other countries with which the UK has double tax treaties. Sometimes treaties include specific provisions relevant to partnerships although generally they do not. If there is specific provision, then you will have to take its terms into account in deciding whether the domestic charge on a partner should be affected at all under the treaty. Where there is no specific provision under the treaty for partnerships you should look at the treaty of the country or countries of residence of each non-resident partner to establish whether the domestic charge on any partner is affected by the relevant treaty.