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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Indirect, capital and transfer taxes and other tax obligations: VAT and partnerships: Inheritance Tax (IHT): General transparency principle

In line with other direct taxes, partnerships are treated as ‘transparent’ for the purposes of IHT. See PM10700 for an explanation of the ‘tax transparency principle’.

As Limited Liability Partnerships (LLPs) are bodies corporate in law, specific provision is made to treat these in the same manner as other partnerships (IHTA 1984/S267A and LLPA 2000/S11).

Where an overseas partnership is involved, you will need to consider whether the particular entity concerned would be regarded as a partnership under UK law.