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HMRC internal manual

Partnership Manual

Mixed member partnerships and international aspects: residence and the tax consequences: Non-resident members: individuals

Where one or more of the partners is a non-resident individual, complications arise where the partnership has worldwide income. UK resident partners will be liable to UK tax on their share of worldwide profits of the partnership. However, non-resident partners will only be liable to UK tax on their share of UK profits. In such a case, two sets of partnership statements should be submitted with the partnership return: one computation based on worldwide profits and one restricted to UK profits only. An example of how this works is available at BIM82235.