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HMRC internal manual

Partnership Manual

Mixed member partnerships and international aspects: Investment partnerships

This term used to describe those partnerships whose business involves the making of and management of investments, rather than carrying on a trade. In the absence of a trading activity, there is no concept of ‘permanent establishment’ or ‘UK representative of non-resident members’. This means that non-resident members are only liable to tax on non-trading income with a UK source, such as rental income from a UK property, interest on a UK bank account or dividends from a UK company.