Taxation of Partnerships

The taxation of partnerships relies on statutory provisions and case law, of course, but is also dependent on HMRC practice and interpretations. This book is a practical guide to the issues arising.

This book is now available in digital format only, with frequent updates and links to legislation, case law and HMRC guidance.

All subscriptions are for a minimum period of one year.

Access this book immediately

• For this book only, click on Subscribe above – monthly direct debit of £12.
• Subscribe to our Complete Tax Library (all our digital content – more than 20 titles) – quarterly direct debit of £295.

Other subscription options

• Subscribe to our Core Tax Library (eight books of your choice) – quarterly direct debit of £195. Email us your choice of eight books.
• Subscribe to our Specialist Tax Library (five books of your choice) – quarterly direct debit of £125. Email us your choice of five books.
• Email us with contact details to ask about multi-user access to some or all of our content.

About this work

Partnership tax issues cut across most of the familiar taxes, but apply them in a particular way.

The book addresses all the key taxes – income tax, capital gains tax, SDLT, corporation tax. It clearly explains the principles applying to different sorts of partnerships (including LLPs, limited partnerships and partnerships with corporate members) and covers the more complex areas including mergers and demergers, incorporations, administration (including partnership returns) etc., losses, capital allowances, and other practical matters arising.

Dedicated chapters look at partnerships with an international dimension, at the issues arising when a partner dies, and at pensions and annuities.

“Thoughtfully examines the key provisions that apply to the taxation of partnerships in a clear and understandable way, with plenty of practical examples and useful tips” – Paula Tallon BBS, FCA, CTA (Fellow), ADIT, TEP, writing in the foreword.

“Through clear and elegant writing, and by avoiding academic theory and focusing on what the typical adviser really needs to know, a large amount of ground is covered” – TAXline, October 2020.

Table of contents

• • Introductory material

• • The nature of partnership

• • Partnership income

• • Partnership losses

• • Capital gains [expanded by way of example]
    • Introduction
    • HMRC guidance and practice [expanded by way of example]
      • Statement of Practice D12
      • Basis of valuation of partnership assets
      • Distribution of partnership assets to the partners
      • Allocation of base cost
      • Change in capital-sharing ratio
      • Revaluation followed by a change in capital-sharing ratio
      • Payment outside the accounts to acquire a partnership share
      • Transfer between persons not at arm’s length
      • Contribution of assets to a partnership
      • Ownership of land, land pooling and exchange of joint interests
      • CGT and LLPs
    • Computation of the gain
    • Gift relief
    • Replacement of business assets relief
    • • Business asset disposal relief

• • Stamp duty land tax

• • Annual tax on enveloped dwellings

• • Incorporation

• • Mergers and demergers

• • Corporate partners

• • Pension contributions and partnership annuities

• • Partnerships with an overseas dimension

• • Partnership tax returns

• • Death and partnerships