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HMRC internal manual

Partnership Manual

Mixed member partnerships and international aspects: UK branches of overseas partnerships

As per the guidance at PM40700, profits earned by a UK branch of an overseas partnership will be taxable on the members regardless of their residence status. However, despite this general rule, you may need to consider how the overseas partnership is classified for the purposes of the UK taxation provisions (see the guidance at PM41100). If the overseas ‘partnership’ is, in fact, classified as an opaque body under the UK provisions, the branch itself will be assessable to corporation tax on its profits.