SALF708 - Self Assessment for Non-Residents: Non-Resident Partners


Changes in the residence status of a partner trigger a deemed commencement or cessation for the purposes of assessing business profits

ICTA88/S112

7.57Section 112 provides that where a member of a partnership either becomes resident, or ceases to be resident in the UK, then for tax purposes that partner is treated as having first ceased and then immediately recommenced as a partner. The rules ensure that resident partners are taxed on their share of the world-wide partnership profits, but non-resident partners only on their share of the profits earned in the UK.
7.58The special rules for foreign partnerships (that is, partnerships controlled and managed abroad) are restated.