Updates: Partnership Manual
2024
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.
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
Allocation examples of profits and losses
Minor formatting update for accessibility
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.
Allocation examples of profits and losses
Minor formatting update for accessibility
Individual, company and non-resident members
Minor formatting update for accessibility
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
Section added to direct readers to relevant information.
Clarification added on the interaction between the mixed membership rules and the loans to participator rules.
Linking partners to the partnership
Page set to published.
Individual, company and non-resident members
Section reformatted.
Change of partnership accounting date
Change to the names used.
Limited liability partnerships: contents
Links to PM131560 archived.
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
No changes made as republished page to prompt change notes update
Individual, company and non-resident members
Grammatical correction.
Examples of partnership computations with indirect partners
Names changed.
Filing date for partnership return
Link to Enquiry Manual corrected.
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.
UK registered partnership with no UK source income or gain
Update to address
2020
Added tab
Included reference to legislation as per manual feedback
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.
The Annual Investment Allowance (AIA)
attempted change to address a mismatch between internal and external page.
The appropriate notional consideration for services
Amended guidance- example 3 wording from 'Example 6' to 'Example 2'.
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.
Corrected Hyperlinks
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.
Template when a partnership receives 5 or more separate income sources from other partnerships
Subtitle added
Template for partners without a UTR
Updated to link to image
Profits and losses computed at partnership level
Image set up as link
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
Profits and losses computed at partnership level
Added link
Computation and assessment: contents
Added another page- PM163015
Self assessment for partnerships: contents
Added extra link
Template for partners without a UTR
Formatted template
Profits and losses computed at partnership level
FA18 simplification guidance added.
Partnerships that include partnerships as partners
Added content for the FA18 simplifications.
Linking partners to the partnership
Change in guidance due to FA18 simplifications.
Link changed too.
Non-resident members: individuals
Updated link
Individual, company and non-resident members
Format text and edit.
The partnership return: contents
Order changed as per references.
Page republished
The Annual Investment Allowance (AIA)
Links updated
Link reset
Tax transparency ‘switched off’
Page republished
Tax transparency ‘switched on’
links reset
Format change
LLP: restriction of relief for LLP members
format changes
Format change
Format changes.
Link added to PAYE manual.
Links reset, minor formatting changes
format change
Format changes
format edit.
links reset, minor formatting changes.
Duplication in Gov.uk not internal manual. Unsure why.
link broken
Change of Regulation number
Format change- Bold titles
Private Fund limited partnerships
added content
Destination table of original partnership guidance
Reference corrections
Examples of partnership computations
Reformatted tables
Change of partnership accounting date
Reformatted tables
Allocation examples of profits and losses
Reformatted tables
Company partners and tax mitigation
slight update
Incorrect content.
Pseudo share schemes/membership benefit schemes
Content change as incorrect content.
Hybrid entities and tax arbitrage
Edit link
Edit link
Summary of filing requirements for partnerships with foreign aspects
Edit link
UK branches of overseas partnerships
Edit link
Tax status of overseas partnerships
Edit links
Composite SA returns for non-resident individual members
Edit link
Edit links
Edit Links
Non-resident company members not trading in the UK
Edit Links
Non-resident company members trading in the UK
edit link
Non-resident members: companies
Edit link
change links
Construction Industry Scheme (CIS)
update links
Class 4 NIC relief for partner's losses
update links
correct link
correcting Links
update link
Valuing the partnership interest
update link
Transfers of partnership assets
correcting links
General transparency principal
update link
update link
Special partnership provisions
update link
correcting link
updating link
correcting links
correcting links
VAT position of partnership contributions
correcting Link
Group VAT registration and partnerships
updating link
VAT and the existence of a partnership
link from .gov to intranet
Destination table of original partnership guidance
Correction of reference.
Links updated
Link updated
Link updated
Links updated
Link updated
Limited liability partnerships: contents
PM131480 added to menu
Links updated
Links updated
Link updated
Links updated
Links updated
Partnerships: mergers and demergers: contents
Review date set
Link updated
Link updated
Links updated
Links updated
Link updated
Links updated
Links updated
The effect of the restrictions?
Link updated
When do the restrictions apply?
Link updated
Link updated
Links updated
Businesses transferred to the partnership: Examples
Link updated
Businesses transferred to the partnership
Updated links
Link updated
Is the profit share influenced by the power to enjoy?
Link updated
Link updated
Arrangements to secure corporation tax rather than income tax treatment
Link updated
Link updated
Links updated
The appropriate notional consideration for services: restriction
Link updated
The appropriate notional consideration for services
Link updated
Links updated
Links updated
Link updated
Links updated
Who is a non-individual partner
Link updated
Links updated
Link updated
Difference in treatment between individuals and non-individuals
Links updated
Computation and allocation of profits
Link updated
Link updated
Changes of partners: loss relief
Links updated
Licence-related losses: exit charge
Links updated
Links updated
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
Links updated
Links updated
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
Links updated
Disputes over allocation of profits and losses to partners
Link updated
Links updated
Links updated
Link updated
Link updated
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
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
Link updated
Link updated
Format and link updated
Mergers and demergers: text of Statement of Practice SP 9/86
Link updated
Link updated
Mergers: cessation of previous business and commencement of new business
Links updated
Mergers and demergers: overview
Links updated
Link updated
Link updated
Husbands, wives, civil partners and minors
Links updated
Link updated
Links updated
Relations that do not constitute a partnership
Links updated
Links updated
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
Links updated
Links updated
Links updated and formatting
Links updated
Link updated
Link updated
Link updated
Venture Capital/Private Equity and the BVCA agreement
Links updated
Limited partnership: restriction of relief for limited partners
Updated links
Limited liability partnerships: contents
Link added
Link added.
The nominated/representative partner
Contents added
Companies in partnership: contents
Added contents
Claims and elections: contents
Added contents
Arrangements to secure corporation tax rather than income tax treatment
Title added
Partnerships: mergers and demergers: contents
Content updated.
Links added.
Links added.
Taxing the profits of a business carried on in partnership
Links added.
Mistake, content moved back.
The partnership return: contents
new contents
voluntary returns
link
indirect partner
Profits and losses computed at partnership level
separate partnership - keep source separate
adjustment
Links added
links added
Links added
Limited partnership: restriction of relief for limited partners
Links added
Venture Capital/Private Equity and the BVCA agreement
Links added
Links added
Links added
Links Added
Links Added
Links added and format changed
Link added
LLP: partners' basis periods, losses and overlap relief
Links added
Links added
Husbands, wives, civil partners and minors
Link added
Links added
Link added
Links added
Mergers and demergers: overview
Links added
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.
Links added
When does a partnership commence?
Other pages linked.
LINKS ADDED
LINKS ADDED
Link added
The partnership return: contents
new link
hyperlink
hyperlink
hyperlink
hyperlink
Individual, company and non-resident members
hyperlink
Costs connected with the capital structure of a business
hyperlink
hyperlink
hyperlink
Computation and assessment: contents
Link added.
hyperlink
Changes of partners: loss relief
Links added.
Licence-related losses: exit charge
Links added.
Profits and losses computed at partnership level
hyperlinks
Link added.
Link added.
hyperlink
Cost of contribution reimbursed to partner
Link added.
An allocation must not create or increase a loss
hyperlink
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.
Formatted.
Change of partnership accounting date
hyperlink
Notional trade and basis periods - sole trader and partnership changes
hyperlink
Links added
Partnership mergers and demergers
hyperlink
hyperlink
hyperlink
The Annual Investment Allowance (AIA)
hyperlink
hyperlink
hyperlink
Claims for capital allowances on partnership assets
hyperlink
hyperlink
Interest paid by the partnership
hyperlinks
hyperlink
Overriding principle on payments to partners
hyperlink
hyperlink
hyperlink
Partnership advances funds to partner
hyperlink
hyperlink
hyperlink
Partner's basis period: losses
hyperlink
Partner's basis period: taxed income
hyprlinks
Partner’s basis period: untaxed income
hyperlinks
hyperlinks
hyperlink
link
Formatted.
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.
Links added.
Disputes over allocation of profits and losses to partners
Links added.
Links added.
Link added.
Links added.
Filing date for partnership return
Formatting
Partners' returns: returning the partnership profit share
Links added.
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.
Links added.
Spelling mistake.
Link added.
Implementation matters: contents
Title amend
Link added.
Anti-avoidance: combined loan facilities
Formatted.
Links added.
Links added.
Link added.
Links added.
Links added.
Formatted.
Link added.
Formatted.
Link added.
Links added.
Links added.
Link added.
Links added.
Links added.
Formatted.
Formatted.
Link added.
Difference in treatment between individuals and non-individuals
Links added.
Computation and allocation of profits
Link added.
Link added.
The effect of the restrictions?
Link added.
When do the restrictions apply?
Link added.
Pseudo share schemes/membership benefit schemes
Formatted.
Link added.
Links added.
Links added.
Businesses transferred to the partnership: Examples
Link added.
Businesses transferred to the partnership
Formatted and links added.
Formatted.
Link added
Formatted.
Is the profit share influenced by the power to enjoy?
Links added.
Link added.
Arrangements to secure corporation tax rather than income tax treatment
Link added.
Link added.
Links added.
The appropriate notional consideration for services: restriction
Link added.
The appropriate notional consideration for services
Links added.
The appropriate notional return on capital
Formatted.
Link added.
Links added.
Links added.
Links added.
Who is a non-individual partner
Link added.
Links added.
Links added.
Link added.
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.
Link added.
Link added.
Links added.
Link added.
Special partnership provisions
Link added.
Link added.
General transparency principal
Link added.
Transfers of partnership assets
Link added.
Valuing the partnership interest
Link added.
Link added.
Links added.
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.
Links added.
Links added
Minor change to a reference number
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.
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
Minor wording changes
2018
Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): introduction
Incorrect reference to VAT