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HMRC internal manual

Partnership Manual

Mixed member partnerships: company partners

There is nothing to prevent companies being partners in partnerships or members of LLPs. In recent years there has been an increase in the number of mixed member partnerships and LLPs, typically companies and individuals. Often partnerships may introduce company partners for reasons unrelated to tax, but in some cases introduction of the company partner is designed to minimise the overall tax paid on the partnership profits. Draft legislation to counter such arrangements was published in December 2013 and will be included in Finance Bill 2014. Further guidance will be published in due course.