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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: computation of profits: partnerships

Under UK domestic law, a partnership is not regarded as an entity in itself, separate from the individual persons making up the partnership (ITTOIA2005\S848).

Each partner’s share of the partnership trading profit or loss is treated as profits or losses of a trade carried on by that partner alone (ITTOIA2005\S852(1)). See BIM72200 for details on computing partnership profits and BIM72010 for HMRC’s approach to joint ventures

If a partner is not resident in the UK, the profits or losses of the trade are calculated as if the partnership were a non UK resident individual (ITTOIA2005\S849(3)). Further details on how the UK domestic tax charge is modified by Double Taxation Agreements is available at DT1750.

The general taxing rules are modified where at least one member of the partnership is a company (see CTM36505).