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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Mixed member partnerships and international aspects: residence and the tax consequences: UK resident members

The taxation of UK resident members of UK partnerships is straightforward in that the members will be assessable to tax on their share of worldwide profits and gains of the partnership, whether arising in the UK or abroad.

However, you may need to consider whether the remittance basis is available on profits earned outside the UK where an individual member is resident but not ordinarily resident or domiciled in the UK. Detailed instructions on this topic are available at RDRM30000 onwards but please also refer to the ‘management and control’ guidance at PM40600.

Note that partners claiming the remittance basis may be liable to the remittance basis charge (RBC) if they are ‘long-term UK residents’. Further details can be found at RDRM32200.