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HMRC internal manual

Oil Taxation Manual

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

Norwegian partnerships, or ‘Kommandlttselskap’ (K/S) are frequently engaged in operations on the UK continental shelf. The K/S is a limited partnership made up of a number of limited liability partners and one or more general partners. The general partners are almost always companies with limited liability (‘Aksjeselskab’ (A/S)) so that effectively they are also limited liability partners. The powers of general partners are defined in the partnership agreement and usually include authority to enter into contracts on behalf of the partnership.

The partnership members are invariably residents of Norway. The methodology described at DT1726 is used to arrive at the amount of profits chargeable to UK tax.