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HMRC internal manual

Partnership Manual

Mixed member partnerships and international aspects: UK registered partnerships with no UK source

In certain circumstances, HMRC may agree that a partnership return is not required. This may apply if the partnership has no UK resident partners, has no income or gains arising in the UK and is managed and controlled outside the UK. If the partnership believes that none of the members will be liable to UK tax, the partnership can supply the following information to HMRC:

  1. In which country is this partnership controlled and managed, and is there any intention to change this?
  2. Does the partnership have or intend to have a UK office or agency?
  3. Does the partnership have or intend to have any source of income arising in the UK (including UK investments)?
  4. Does the partnership own or intend to own any UK property?
  5. Does the partnership hold or intend to hold any assets in the UK?
  6. Does the partnership have or intend to have any partners that are resident in the UK?
  7. What is the principal activity of the partnership and, if this is carried on wholly outside the UK, why has the partnership been established in the UK?

Correspondence should be sent to HM Revenue & Customs, PAYE and Self Assessment, PO Box 4000, Cardiff.