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HMRC internal manual

Partnership Manual

From
HM Revenue & Customs
Updated
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Introduction to Partnerships and Partnership Taxation: relations that do not constitute a partnership

Not all associations between persons for business purposes constitute partnerships. An arrangement which falls short of a partnership is often called a joint venture. Business associates may claim that their relationship is only a joint venture and not a partnership. It is most likely that you have a joint venture and not a partnership in cases:

  • where two or more persons, already carrying on a business of their own, co-operate in some way on a single project

but

  • do not calculate and share the net profits or losses resulting from this.
     

Further guidance on joint ventures is available at BIM82010.

The letting of jointly owned property does not normally constitute a partnership. Most cases will fall short of the degree of business organisation needed to constitute a business. The provision of significant additional services in return for payment may be an indicator of such business organisation. Additional guidance is available at PIM1030