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HMRC internal manual

Partnership Manual

From
HM Revenue & Customs
Updated
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Limited Liability Partnerships: statutory provisions for tax transparency: tax transparency ‘switched on’

As an LLP is a body corporate, statutory provisions exist to ensure that LLPs are treated like partnerships and transparent for specified tax purposes. These are contained at ITTOIA2005/S863 (income tax) and CTA2009/S1273 (corporation tax) for income and TCGA/S59A for gains. Detailed guidance is available at BIM82115 and CG27050.