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Home / Simons-Taxes /IHT, trusts and estates /Part I6 Close companies and partnerships /Division I6.2 Partnerships and IHT /Partnerships and IHT—the basics / I6.201 Partnerships and IHT—overview
Commentary

I6.201 Partnerships and IHT—overview

IHT, trusts and estates

For updates affecting this Division please see Part I0 Updates

Partnerships and IHT—the basics

I6.201 Partnerships and IHT—overview

For further commentary on partnerships and other taxes see the following Divisions:

What is a partnership?Division B7.1
Computation of partnership income and gainsDivision B7.4
Taxation of partnership income and gainsDivision B7.5

English partnerships

Under English law, the term 'partnership' merely describes the relationship which subsists between two or more persons who carry on business together with a view to profit1. Such a partnership is not a separate legal entity, distinct from the individual partners. The rights and liabilities of a partnership are simply the aggregate of the rights and liabilities of the partners.

A partner is directly interested in each and every asset of his partnership, and participates directly in its profits. Contrast this with a shareholder in a company — he owns an asset (his shareholding) which is quite separate from the assets of the company, and is entitled to participate in the company's profits

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