Updates: Partnership Manual

2024

21 February 2024 published amendments

Anti-avoidance: genuine finance

Edited PM259310. Change clarifies that even if an arrangement results in a genuine contribution by the individual to the LLP if there is a main purpose of securing the salaried members rules do not apply then the TAAR can still be triggered.

Becoming a member

Example added to show how the legislation applies to arrangements where members alter their capital contributions in order to ensure they don't meet Condition C.

2023

16 May 2023 published amendments

Allocation examples of profits and losses

Minor formatting update for accessibility

9 February 2023 published amendments

Losses and overlap relief

Minor formatting update for accessibility

Examples of partnership computations with indirect partners

Minor formatting update for accessibility

Examples of partnership computations

Minor formatting update for accessibility

Interest paid by the partnership

Spelling mistake corrected.

2 February 2023 published amendments

Allocation examples of profits and losses

Minor formatting update for accessibility

Individual, company and non-resident members

Minor formatting update for accessibility

Mergers: example

Minor formatting update for accessibility

Limited partnership: restriction of relief for limited partners

Minor formatting update for accessibility

Destination table of original partnership guidance

Minor formatting update for accessibility

2022

8 November 2022 published amendments

Mixed member rules: contents

Section added to direct readers to relevant information.

Loans to participators

Clarification added on the interaction between the mixed membership rules and the loans to participator rules.

8 September 2022 published amendments

Linking partners to the partnership

Page set to published.

31 May 2022 published amendments

30 May 2022 published amendments

Change of partnership accounting date

Change to the names used.

26 May 2022 published amendments

Limited liability partnerships: contents

Links to PM131560 archived.

16 February 2022 published amendments

Computation and assessment: contents

Section on averaging added at PM16163195. The page directs readers to the Business Income Manual at BIM84000 onward for more information on averaging.

National Insurance Contributions (NICs)

First paragraph added to this section from the Business Income Manual. The section will be removed from the BIM and replaced with a signpost to the Partnership Manual.

Overview of types of partnership: contents

Section on joint ventures added from the Business Income Manual.

2021

15 December 2021 published amendments

Partnership Manual

No changes made as republished page to prompt change notes update

22 November 2021 published amendments

10 November 2021 published amendments

9 November 2021 published amendments

LLP: overview

This page contained an incorrect link. The previous guidance referred readers to PM131450 for information on bodies formed outside of the UK called Limited Liability Partnerships. This has been changed to PM131540.

29 March 2021 published amendments

2020

17 November 2020 published amendments

13 November 2020 published amendments

Changes of partners

Included reference to legislation as per manual feedback

12 November 2020 published amendments

Disputes over allocation of profits and losses to partners

Updated guidance to include further information to support partners with the details of the dispute process.

4 November 2020 published amendments

The Annual Investment Allowance (AIA)

attempted change to address a mismatch between internal and external page.

15 October 2020 published amendments

The appropriate notional consideration for services

Amended guidance- example 3 wording from 'Example 6' to 'Example 2'.

19 August 2020 published amendments

LLP: Taxation

Included reference to transparency and group relief. Also flagging up difference between a salaried partner and salaried member. Include reference and link to salaried member guidance.

29 July 2020 published amendments

Capital gain reliefs

Corrected Hyperlinks

21 May 2020 published amendments

Functions of financial businesses regulated by Financial Conduct Authority (FCA)

Changes to guidance made to reflect the new FCA’s Approved Persons regime, and explain how this interacts with Condition B of the Salaried Member Rules.

2 January 2020 published amendments

Template for partners without a UTR

Short title added

Profits and losses computed at partnership level

Republish as per CDIO Digital services advice as the changes have not been published to the Gov.UK version.

2019

22 December 2019 published amendments

20 December 2019 published amendments

18 December 2019 published amendments

Profits and losses computed at partnership level

FA18 simplification guidance added.

Partnerships that include partnerships as partners

Added content for the FA18 simplifications.

17 December 2019 published amendments

Linking partners to the partnership

Change in guidance due to FA18 simplifications.

Link changed too.

Non-resident members: individuals

Updated link

30 October 2019 published amendments

Individual, company and non-resident members

Format text and edit.

The partnership return: contents

Order changed as per references.

18 October 2019 published amendments

LLP: Compliance

Page republished

15 October 2019 published amendments

9 October 2019 published amendments

8 October 2019 published amendments

LLP: International aspects

Format change

LLP: restriction of relief for LLP members

format changes

LLP: partners interest relief

Format change

LLP: Computation of profits

Format changes.

LLP: Compliance

Link added to PAYE manual.

LLP: Taxation

Links reset, minor formatting changes

LLP: Agreement

format change

LLP: Types of member

Format changes

LLP: overview

format edit.

LLP: Conversions

links reset, minor formatting changes.

3 October 2019 published amendments

LLP: Conversions

Duplication in Gov.uk not internal manual. Unsure why.

Profit sharing arrangements

link broken

LLP: Agreement

Change of Regulation number

1 October 2019 published amendments

Introduction

Format change- Bold titles

15 August 2019 published amendments

14 August 2019 published amendments

5 August 2019 published amendments

29 July 2019 published amendments

26 July 2019 published amendments

International structures

Incorrect content.

Pseudo share schemes/membership benefit schemes

Content change as incorrect content.

5 July 2019 published amendments

2 July 2019 published amendments

Significant influence

Links updated

Profits from the UK LLP

Link updated

Working for the UK LLP

Link updated

Overview

Links updated

Compliance and PAYE failure

Link updated

Limited liability partnerships: contents

PM131480 added to menu

Overview

Links updated

Overview

Links updated

Deemed contributions

Link updated

When to apply the test

Links updated

Overview

Links updated

Partnerships: mergers and demergers: contents

Review date set

Hierarchy of members

Link updated

The LLP agreement

Link updated

Overview

Links updated

Fees generated

Links updated

Relevant period

Link updated

Relevant arrangements

Links updated

Condition A- overview

Links updated

The effect of the restrictions?

Link updated

When do the restrictions apply?

Link updated

Share issues

Link updated

Private equity investment

Links updated

Businesses transferred to the partnership: Examples

Link updated

Businesses transferred to the partnership

Updated links

Reallocations: Individuals

Link updated

Is the profit share influenced by the power to enjoy?

Link updated

Enjoyment Conditions

Link updated

Arrangements to secure corporation tax rather than income tax treatment

Link updated

Connected parties

Link updated

The power to enjoy

Links updated

The appropriate notional consideration for services: restriction

Link updated

The appropriate notional consideration for services

Link updated

Appropriate notional profit

Links updated

Condition Y

Links updated

Condition X

Link updated

When do the rules apply?

Links updated

Who is a non-individual partner

Link updated

Overview

Links updated

Loans to participators

Link updated

Difference in treatment between individuals and non-individuals

Links updated

Computation and allocation of profits

Link updated

Companies in partnership

Link updated

Changes of partners: loss relief

Links updated

Licence-related losses: exit charge

Links updated

Recovery of excess relief

Links updated

Exemptions

Link updated

Cost of contribution reimbursed to partner

Link updated

Risk-free capital contributions

Links updated

Non-active partners: unrelieved amounts

Links updated

Non-active partners in early tax years: example

Link updated

Non-active partners in early tax years

Links updated

Unrelieved amounts

Links updated

LLP members

Links updated

Limited Partners

Links updated

Calculation of limit relief: £25,000 annual limit

Links updated

Calculation of limit relief: partners' capital contribution

Links updated

Claims and elections that affect partnership profits

Link updated

Introduction

Links updated

Disputes over allocation of profits and losses to partners

Link updated

Information powers

Links updated

Opening a compliance check

Links updated

Review and liaison

Link updated

Introduction

Link updated

Late filing penalties

Links updated

Filing date for partnership return

Links updated

Composite returns for individual non-resident partners

Link change

Partners' returns: returning the partnership profit share

Links updated

Operational guidance

Link updated

Standard Accounts Information (SAI) or full accounts and computation

Link updated

Registration of partners with HMRC

Links updated

The partnership return: requirements

Links updated

The nominated/representative partner

Link pdated

The legal framework

Link updated

How partners are taxed

Link updated

Profit sharing arrangements

Format and link updated

Mergers and demergers: text of Statement of Practice SP 9/86

Link updated

Mergers: example

Link updated

Mergers: cessation of previous business and commencement of new business

Links updated

Mergers and demergers: overview

Links updated

Partnerships - dissolution

Link updated

Does a partnership exist?

Link updated

Husbands, wives, civil partners and minors

Links updated

Types of partner

Link updated

Partners: overview

Links updated

Relations that do not constitute a partnership

Links updated

Scottish partnerships

Links updated

LLP: NIC

Links updated

LLP: partners' basis periods, losses and overlap relief

Links updated

LLP: restriction of relief for LLP members

Links updated

Tax transparency ‘switched on’

Link updated

LLP: Computation of profits

Links updated

LLP: Compliance

Links updated

LLP: Taxation

Links updated and formatting

LLP: Conversions

Links updated

LLP: Types of member

Link updated

LLP: overview

Link updated

Nominee members

Link updated

Venture Capital/Private Equity and the BVCA agreement

Links updated

Limited partnership: restriction of relief for limited partners

Updated links

28 June 2019 published amendments

27 June 2019 published amendments

Basis period rules

link

Partner's notional trade

indirect partner

Profits and losses computed at partnership level

separate partnership - keep source separate

LLP: Types of member

adjustment

21 June 2019 published amendments

20 June 2019 published amendments

Nominee members

Links added

Limited partnership: overview

links added

LLP: Types of member

Links added

Limited partnership: restriction of relief for limited partners

Links added

Venture Capital/Private Equity and the BVCA agreement

Links added

LLP: Conversions

Links added

LLP: Agreement

Links added

LLP: Computation of profits

Links Added

LLP: overview

Links Added

LLP: Taxation

Links added and format changed

LLP: Compliance

Link added

LLP: partners' basis periods, losses and overlap relief

Links added

Scottish partnerships

Links added

Husbands, wives, civil partners and minors

Link added

Partners: overview

Links added

Partnerships - dissolution

Link added

Types of partner

Links added

Mergers and demergers: overview

Links added

Does a partnership exist?

Link added

Relations that do not constitute a partnership

Links added

Mergers: cessation of previous business and commencement of new business

Links added

Mergers: previous businesses continue as a merged joint business

Links added

Mergers: cessation of one business and the continuation of the other business

Link added

LLP: restriction of relief for LLP members

Links added.

Mergers: example

Links added

When does a partnership commence?

Other pages linked.

What is a partnership?

LINKS ADDED

Introduction

LINKS ADDED

Who is a partner?

Link added

The partnership return: contents

new link

Termination payments

hyperlink

The partnership

hyperlink

Leasing

hyperlink

Partner's notional trade

hyperlink

Individual, company and non-resident members

hyperlink

Costs connected with the capital structure of a business

hyperlink

Retired partners

hyperlink

Service companies

hyperlink

Computation and assessment: contents

Link added.

Property

hyperlink

Changes of partners: loss relief

Links added.

Licence-related losses: exit charge

Links added.

Profits and losses computed at partnership level

hyperlinks

Recovery of excess relief

Link added.

Exemptions

Link added.

Changes of partners

hyperlink

Cost of contribution reimbursed to partner

Link added.

An allocation must not create or increase a loss

hyperlink

Basis period rules

hyperlink

Risk-free capital contributions

Links added.

Non-active partners: unrelieved amounts

Links added.

Non-active partners in early tax years: example

Link added.

Non-active partners in early tax years

Links added.

Unrelieved amounts

Formatted.

Change of partnership accounting date

hyperlink

Notional trade and basis periods - sole trader and partnership changes

hyperlink

LLP members

Links added

Partnership mergers and demergers

hyperlink

Accounting date changes

hyperlink

Trading profits: overlap

hyperlink

The Annual Investment Allowance (AIA)

hyperlink

Connected persons

hyperlink

Partnership changes

hyperlink

Claims for capital allowances on partnership assets

hyperlink

Rent

hyperlink

Interest paid by the partnership

hyperlinks

Partner training costs

hyperlink

Overriding principle on payments to partners

hyperlink

Partners' personal expenses

hyperlink

Expenses paid by partners

hyperlink

Partnership advances funds to partner

hyperlink

19 June 2019 published amendments

Retired partners

hyperlink

Overlap relief

hyperlink

Partner's basis period: losses

hyperlink

Partner's basis period: taxed income

hyprlinks

Partner’s basis period: untaxed income

hyperlinks

Partner's basis periods

hyperlinks

Allocation of income

hyperlink

Computation of income

link

Limited partners: examples

Formatted.

Limited Partners

Links added.

Calculation of limit relief: £25,000 annual limit

Links added.

Calculation of limit relief: partners' capital contribution

Links added.

Claims and elections that affect partnership profits

Link added.

Introduction

Links added.

Disputes over allocation of profits and losses to partners

Links added.

Information powers

Links added.

Opening a compliance check

Link added.

Late filing penalties

Links added.

Filing date for partnership return

Formatting

Partners' returns: returning the partnership profit share

Links added.

Operational guidance

Link added.

Standard Accounts Information (SAI) or full accounts and computation

Link added.

The partnership return: requirements

Links added.

Linking partners to the partnership

Link added.

The legal framework

Links added.

Significant influence

Spelling mistake.

Income from other firms

Link added.

Implementation matters: contents

Title amend

Compliance and PAYE failure

Link added.

Anti-avoidance: combined loan facilities

Formatted.

Overview

Links added.

Overview

Links added.

Deemed contributions

Link added.

When to apply the test

Links added.

Overview

Links added.

Change in circumstances

Formatted.

Hierarchy of members

Link added.

Significance of size

Formatted.

The LLP agreement

Link added.

Overview

Links added.

Fees generated

Links added.

Relevant period

Link added.

Relevant arrangements

Links added.

Condition A- overview

Links added.

Who can be a salaried member?

Formatted.

The salaried member guidance

Formatted.

17 June 2019 published amendments

Overview

Links added.

Working for the UK LLP

Link added.

Profits from the UK LLP

Spelling mistake.

VAT and the existence of a partnership

Links updated.

Group VAT registration and partnerships

Link added.

VAT position of partnership contributions

Link added.

Capital gains- introduction

Link added.

Goodwill

Link added.

Capital gain reliefs

Links added.

SDLT and partnerships

Link added.

Special partnership provisions

Link added.

SDLT avoidance

Link added.

General transparency principal

Link added.

Transfers of partnership assets

Link added.

Valuing the partnership interest

Link added.

Situs of partnership interest

Link added.

Business property relief

Links added.

PAYE

Link added.

Class 4 NIC relief for partner's losses

Links added.

Construction Industry Scheme (CIS)

Links added

Composite SA returns for non-resident individual members

Links added.

Where are the profits earned?

Links added.

Management and control

Links added

Partners' personal expenses

Minor change to a reference number

UK resident members

Links added.

Non-resident members: companies

Links added.

Non-resident company members trading in the UK

Links added.

Non-resident company members not trading in the UK

Links added.

Hybrid entities and tax arbitrage

Link added.

Double taxation

Link added.

Summary of filing requirements for partnerships with foreign aspects

Links added

UK branches of overseas partnerships

Links added.

Tax status of overseas partnerships

Links added

Expenses paid by partners

Minor wording changes

2018

9 November 2018 published amendments