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Official guidance
Company Taxation Manual

CTM36500 · Particular topics: companies in partnership

  • CTM36505 · Introduction
  • CTM36510 · Computation of profits and losses
  • CTM36520 · Different classes of partner
  • CTM36530 · Loan relationships etc
  • CTM36540 · Interest paid etc
  • CTM36550 · Limited and limited liability partnerships
  • CTM36560 · Investment partnerships
  • CTM36570 · Investment partnerships: procedures for
  • CTM36580 · British Venture Capital Association statement and guidelines
  • CTM36590 · Transfer of relief between companies and partnerships
  1. Particular topics: companies in partnership: contents
  2. Particular topics: companies in partnership: introduction

CTM36505 | Particular topics: companies in partnership: introduction

From HM Revenue & Customs · Company Taxation Manual

Companies may form partnerships with other legal persons including individuals, other companies and trustees. For tax purposes, a ‘company partnership’ is a partnership in which at least one member is a company.

Each company member liable to UK CT is required to include in its CTSA return the share of profits it derives from the partnership.

In partnership return context the term ‘CT partnership’ is used to describe a partnership all of whose members are within the charge to CT.

For guidance on:

  • the nature and conduct of partnerships generally: see PM130000 onwards;

  • computation of tax liability of company members (CTA09/PART17): see CTM36510 to CTM36540;

  • computation of tax liability of members who are individuals: see PM162000 onwards;

  • limited partnerships: see CTM36550 and PM131300;

  • limited liability partnerships: see CTM36550 and PM131400;

  • restriction of the losses of limited partners and LLP partners (ITA07/S117 and CTA10/S56CTA10): CTM36550, BIM82105 and BIM82135;

  • investment partnerships: see CTM36560 and CTM36570;

  • CG of partners (TCGA92/S59): see CG27000 onwards;

  • foreign partnerships with company members: see CTM02130;

  • arrangements for transferring relief between partners (CTA10/S960): see CTM36590.

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