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Limited liability partnerships (LLPs) are in law regarded as bodies corporate and are subject to aspects of company law, but for tax purposes they are generally treated as partnerships, see more details in B7.107 and PM131400 onwards. LLPs are normally treated as transparent for tax purposes provided the LLP is carrying on 'a trade, profession or business with a view to profit'. Members of an LLP are assessed to tax on their share of the LLP's income or gains as if they were members of a general partnership governed by the Partnership Act 1890. Although, note that this general rule is subject to the salaried member rules, see B7.514.

Where an LLP carries on a trade, profession or business with a view to profit, for tax purposes¹:

1. Ìý

   •ÌýÌýÌýÌý all the activities of the LLP (whether or not in the course of a trade etc) are treated as carried on in partnership by its members and not by the LLP as such

2. Ìý

   •ÌýÌýÌýÌý anything done by, to or in relation to the LLP