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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Introduction to Partnerships and Partnership Taxation: does a partnership exist?

In determining whether a partnership exists, the starting point is the statutory definition. It is important to establish all the relevant facts to determine the true relationship between the parties, including finding out what the intentions of the parties were. An overall view will need to be formed as no single factor is likely to be conclusive on its own. For example, a mere assertion that a partnership exists is not conclusive if there is no supporting evidence. A written partnership agreement may provide evidence that a partnership exists but, again, it is not a conclusive factor on its own. Detailed guidance is available at BIM82005.