Partnerships

Walter Sinclair and Barry Lipkin

Chapter Chapter 12 in St. James’s Place Wealth Management Tax Guide 2012–2013, 2012, pp 152-156 from Palgrave Macmillan

Abstract: Abstract Special rules relate to the taxation of partnerships and these are covered in the following sections. Note that the present system operates generally from 1997–98 and for partnerships starting after 5 April 1994 (12.2). From 2005– 06, rewritten legislation is applied by Ss846–863 in ITTOIA (2.10). Partnership is the relationship which exists between two or more persons in business together with the object of making profits. There does not necessarily have to be a written partnership agreement but the partnership must exist in fact. If no partnership is in fact operating then, even though there may be a written agreement, it would not make the partnership exist. Since the assessment of a partnership differs from that of an individual in certain respects, HMRC will seek to establish whether a partnership in fact exists.

Keywords: Capital Gain; Special Rule; Limited Liability; Investment Income; Share Ratio (search for similar items in EconPapers)
Date: 2012
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DOI: 10.1057/9781137290809_12

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