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HMRC internal manual

Partnership Manual

Limited partnerships and limited liability partnerships: nominee members

You may come across cases when it is claimed that a person registered as a member of an LP or an LLP is a nominee for one or other persons. In some instances, it is argued that this person is not taxable on the share of partnership profit allocated to them as he or she is not beneficially entitled to those profits. In such cases it will be necessary to determine who is the member or partner- guidance is at BIM82110.