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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Mixed member partnerships and international aspects: Double Taxation

You may need to consider the terms of a double taxation agreement (DTA) where a partnership has non-resident members and/or the business is carried on in more than one jurisdiction. Issues may arise over who can claim double taxation relief (DTR), depending on whether the partnership is treated as a taxable person in the other country. You should also seek further advice in respect of any claims that a share of UK partnerships profits is not taxable due to the terms of a DTA. You can find more detailed guidance at DT1750.