The general partnership charging rules are applied to a non-UK resident member of a partnership in such a way as to ensure that the partner is taxed only on their share of profits earned in the UK1 (whereas UK resident partners are taxed on their share of worldwide profits). Further details can be found in Ray: Partnership Taxation, Ch 16 and 19.54.
Non-resident corporate partners
For corporate tax purposes (ie where there is a non-resident corporate partner), a separate computation of the partnership profits has to be made on the basis that the partnership is itself a non-resident company, ie on the basis that it was carrying on business in the UK through a permanent establishment. The profit or loss of a non-resident corporate member is its share of the profit so computed2. This restricts the non-resident company's liability to UK corporation tax to its share of the partnership's UK-source profit3.
Special rules apply in the case of non-UK resident companies that are members of a partnership whose sole activity
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