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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. UK registered partnership with no UK source income or gain

PM287000 | UK registered partnership with no UK source income or gain

From HM Revenue & Customs · Partnership Manual

In certain circumstances, HMRC may agree that a partnership return is not required. This may apply if the partnership has no UK resident partners, has no income or gains arising in the UK and is managed and controlled outside the UK. If the partnership believes that none of the members will be liable to UK tax, the partnership can supply the following information to HMRC:

  1. In which country is this partnership controlled and managed, and is there any intention to change this?

  2. Does the partnership have or intend to have a UK office or agency?

  3. Does the partnership have or intend to have any source of income arising in the UK (including UK investments)?

  4. Does the partnership own or intend to own any UK property?

  5. Does the partnership hold or intend to hold any assets in the UK?

  6. Does the partnership have or intend to have any partners that are resident in the UK?

  7. What is the principal activity of the partnership and, if this is carried on wholly outside the UK, why has the partnership been established in the UK?

Correspondence should be sent to PAYE and Self Assessment, HM Revenue & Customs, BX9 1AS.

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