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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Limited partnerships and limited liability partnerships: distinct legal personality and Taxes Management provisions

This note applies to any type of partnership that has distinct legal personality. In practice, you will most often come across this when looking at LLPs and some types of LP. A Limited Partnership formed under English law does not have legal personality but Limited Partnerships formed in other legal jurisdictions do.

In law, a partnership with distinct legal personality can be a member of another partnership. HMRC’s view is that this is respected for the purposes of any provisions of the Taxes Acts that require disclosure of the members of the partnership, such as the partnership statement forming part of the annual tax return.