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HMRC internal manual

Partnership Manual

Capital gains- introduction

Detailed guidance on partnership specific capital gains issues is available at CG27000 onwards. In particular, you should be aware of Statement of Practice D12, which explains how HMRC applies the relevant legislation in practice.


As a brief introduction, transactions in partnership assets are treated as made by the partners rather than by the partnership (TCGA92/S59 and S59A). Tax on chargeable gains accruing to the partners on disposals of their interests in partnership assets are charged on the partners themselves, not on the partnership.


Note that disposals of a partnership’s chargeable assets should be disclosed on the partnership return, with the resultant gain/loss arising or accruing to each partner reflected on their own tax return. However, a partner’s disposal of their interest in the partnership’s assets need only be returned on their own tax return.


Please see the following pages for goodwill and capital gains reliefs.