This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Partnership Manual

Calculating the taxable profits: costs connected with the capital structure of a business

Fees incurred in connection with the acquisition, alteration or enhancement of how the ownership of a business is structured should generally be disallowed as the costs are regarded as capital expenditure for tax purposes. This will include costs incurred on:

  • forming, varying or dissolving a partnership
  • the incorporation of a partnership’s business (to a limited company)
  • a partnership becoming a limited liability partnership (LLP)

Further guidance is available at BIM35525.