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HMRC internal manual

Partnership Manual

Mixed member partnerships and international aspects: residence and the tax consequences: Non-resident company members trading in the UK

Any non-resident company trading in the UK through a permanent establishment or agent must make corporation tax (CT) returns.

This rule will apply where the non-resident company is a member of a partnership whose business includes carrying on a trade in the UK. Every partner is the agent of his fellow-partners for the purpose of the partnership business so a partner may ‘carry on business’ through fellow-partners as their agent without playing any active part in the business itself. The company will be liable to CT on its share of the partnership profits. Please refer to PM40470 if the company also has non-trading UK income which is not connected to the permanent establishment.