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HMRC internal manual

Self Assessment: the legal framework

Self Assessment for non-residents: non-resident partners

Changes in the residence status of a partner trigger a deemed commencement or cessation for the purposes of assessing business profits


Section 112 provides that where a member of a partnership either becomes resident, or ceases to be resident in the UK, then for tax purposes that partner is treated as having first ceased and then immediately recommenced as a partner. The rules ensure that resident partners are taxed on their share of the world-wide partnership profits, but non-resident partners only on their share of the profits earned in the UK.

The special rules for foreign partnerships (that is, partnerships controlled and managed abroad) are restated.