A Partnership is a relatively simple way for two or more legal persons to set up and run a business together with a view to profit. Partnerships can take many forms. Legal persons other than individuals can also be partners in a partnership. For example, companies may form partnerships with other legal persons including individuals, other companies and trustees. For tax purposes, a ‘company partnership’ is a partnership in which at least one member is a company.
A company in a partnership is treated like any other partner except that they have additional tax and reporting obligations. This means that each company member liable to UK Corporation Tax (CT) is required to include in its CTSA return the share of profits it derives from the partnership.
In partnership return context the term ‘CT partnership’ is used to describe a partnership all of whose members are within the charge to CT.
The CT charged on a company partner in respect of its share of partnership profits is not a partnership debt. None of the other partners are therefore liable for that tax.