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HMRC internal manual

Partnership Manual

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

In certain circumstances LLPs are not treated as transparent for tax purposes. Detailed guidance is at BIM82115 and CG27050).


  • the LLP’s business is not being carried on with a view to profit, or
  • the LLP is in liquidation,

the LLP will be treated as a body corporate for tax purposes and any chargeable income or gains arising will be liable to corporation tax, payable by the LLP itself.

This will not apply if there is only a temporary cessation in carrying on business with a view to profit or if the LLP is being informally wound up and the winding up is not unnecessarily prolonged or connected with the avoidance of tax.