HMRC internal manual

Partnership Manual

PM131485 - Tax transparency ‘switched on’

As an LLP is a body corporate, statutory provisions exist to ensure that LLPs are treated like partnerships and transparent for specified tax purposes. These are contained at ITTOIA2005/S863 (income tax) and CTA2009/S1273 (corporation tax) for income and TCGA/S59A for gains. Detailed guidance is available at PM131450 and CG27050.