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HMRC internal manual

VAT Cost Sharing Exemption Manual

How the conditions are to be interpreted: Some particular forms of Cost Sharing Groups: What about the different legal status of partnerships in Scotland and the rest of the UK?

In Scotland a partnership has a separate legal personality from its members. In the rest of the UK that is not the case. However the effect of s45 of the VAT Act 1994 is to treat partnerships as a separate person for VAT purposes. It is possible therefore for members of a UK partnership to be treated as separate taxable persons from a partnership that is also registered for VAT.