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HMRC internal manual

VAT Single Entity and Disaggregation

From
HM Revenue & Customs
Updated
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Single Entity and Partnerships: contract and intention

A partnership is the relationship resulting from a contract, either express or implied. In determining the existence of a partnership, you must pay regard to the true contract or intention of the parties as it appears from all the circumstances of the case. The ‘true contract and intention’ is often a matter of fact.