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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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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.