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

HMRC internal manual

Partnership Manual

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

The tax treatment of non-resident company members will depend on whether a trade is conducted through the partnership within the UK.

Please refer to the guidance at PM40465 where there is trading activity in the UK and at PM40470 where there is no UK trading activity.