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Contents

Official guidance
Partnership Manual

PM280000 · Overseas partnerships & treatment for UK tax purposes

  • PM281100 · UK resident members
  • PM281200 · Non-resident members: individuals
  • PM281300 · Non-resident members: companies
  • PM281400 · Non-resident company members trading in the UK
  • PM281500 · Non-resident company members not trading in the UK
  • PM282000 · Certificates of residence
  • PM283000 · Management and control
  • PM284000 · Where are the profits earned?
  • PM285000 · Composite SA returns for non-resident individual members
  • PM286000 · Investment partnerships
  • PM287000 · UK registered partnership with no UK source income or gain
  • PM288000 · Tax status of overseas partnerships
  • PM289000 · UK branches of overseas partnerships
  • PM290000 · Summary of filing requirements for partnerships with foreign aspects
  • PM291000 · Double taxation
  • PM292000 · Hybrid entities and tax arbitrage
  • PM293000 · Overseas partners in investment partnerships
  1. Overseas partnerships & treatment for UK tax purposes: contents
  2. Investment partnerships

PM286000 | Investment partnerships

From HM Revenue & Customs · Partnership Manual

This term is used to describe those partnerships whose business involves the making of and management of investments, rather than carrying on a trade. In the absence of a trading activity, there is no concept of ‘permanent establishment’ or ‘UK representative of non-resident members’. This means that non-resident members are only liable to tax on non-trading income with a UK source, such as rental income from a UK property, interest on a UK bank account or dividends from a UK company.

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