– see also Solicitors; Sole traders

£25,000 cap

'see-through' analysis

Accounting basis

Accounting periods

Activities of a company as a member

Adjustment income

Admission and retirement of partners

Admission of new partner, supply of services for consideration

Admission of partner in return for capital payment

Agreement

Agricultural property relief

Accruer arrangements

Generally

Limited partnerships

Occupation by

Occupation for two years

Qualification for relief

Rate of relief

Replacement

Transfers made before 10 March 1981

Alleged cessation of trade

Allocation of profits or losses

Change in profit sharing arrangements

Corporate partners

Generally

Interest on capital

Loan relationship debit and credits

Reallocation

Salaries

Untaxed income

Annual tax on enveloped dwellings

Annuities

Annuities provided by

Anti-avoidance

Generally

Anti-avoidance provisions, non-active partners

Application to

Apportionment of income

Arrangements

Ascertaining income shares

Assessment

Assessments

Business constituting a partnership

Change of name

Generally

Made against individual partners

Assessments, time-limits

Asset based approach, Lady Fox case

Assets

Generally

Let to, replacement

Rebasing rules for disposals before, on or after 6 April 2008

Assurance policies, inheritance tax

Avoidance schemes

Bare trusts

Basic principles

Basis periods for partner's notional trade

Business carried on by

Business carried on in Jersey, double taxation relief

Business property relief

Accruer arrangements

Buy and sell agreements

Buy or sell agreements

Property of transferor used by

Replacement

Transfer of assets

Buy and sell agreements

Calculation of firm's profits or losses

Allocation between partners

Generally

Loss-making period

Non-trading income

Partners' shares

Profit-making period

Qualifying film expenditure, meaning

Calculation of profits and losses

Accounting periods

Allocation between partners

Apportionment of profit share between partner's accounting periods

Generally

Loss-making period in which some partners have profits

Profit-making period in which some partners have losses

Capital

Cost of raising, input tax

Introduction

Capital allowances

Capital contribution (restriction to amount of)

Capital gains tax

Accounting adjustments

Assessments

Assets

Assets received in kind

Generally

Partnership sharing ratios, changes

Payments outside accounts

Residence

Transfers not at arm's length

Capital gains tax, general provisions

Carrying on a 'business'

Case stated, proper appellant

Change in partners

Change in partnership asset-sharing ratios

Change of accounting basis

Generally

Changes in circumstances, notification

Changes in sharing ratios

Changes in tax rules

Character

Chargeable gains

Charge to tax

Companies

Disposal to a third party, asset-sharing ratio

Replacement of business assets

Residence

Retirement relief

Transfer of an asset by a partner to the partnership

Chargeable interests

Interpretation

Transfers from partnerships

Transfers of partnership interests

Transfers to partnerships

Chargeable transactions

Civil fraud penalty

Civil partners

Claims

Class 4 contributions

– see also Class 4 contributions

Generally

Closure notice

Validity

Commencement or cessation of partner's notional trade

Commissioners' regulations

Companies

Company

Generally

Leasing plant and machinery, restriction on use of losses

Loan relationships

Overpaid tax, recovery of

Company members

Competent appellant

Compliance

Compliance issues

Connected persons

Consequences of

Consideration

Capital introduced

Share, purchase and disposal

Continuation election

Contribution of asset

Controlling member, meaning

Corporate partners

Corporation tax overview

Cost of raising capital, input tax

Costs of recruiting new partners

Creation

Conversion to LLP status

Date exist

De-registration

Dissolved partnership and cash accounting scheme

Formation or cessation of partnership

Deduction for deemed employment payment

Deduction of tax at source, excepted payments

Deemed

Cessation

Generally

Deemed employment payment, deduction for

Default surcharge, reasonable excuse

Definition

Derivative contracts

Determination of credits and debits

Fair value accounting

Generally

Determination, estimated and further assessments

Direct interest company, meaning

Directors' fees

Disposal of assets

Disposal of business on retirement

Disposals

Background

Disposals of income streams

Disposals of assets

Dissolution

Consequences

Generally

Limited liability partnership

Dissolution, partner's liability for VAT

Distribution of assets

Double taxation agreements

Dual residence

Duration of

Earnings basis, Walton case

EEIGs

Election by property investment partnership to disapply para. 10

Elections

Employee share ownership plans

Employment and

Enquiries

– see Enquiries

Equity partners

Errors, penalty

European Economic Interest Groupings

Excess loss allocations

Exchanges of land

Existence

Case examples

Estoppel

Generally

Validity of assessment

FA 2003, Sch. 15, Part 3 scope

Development of the provisions

Stamp duty

FA 2004 provisions

Family

Family investment companies (as alternative)

Family members

Farming

Film loss relief

Capital contribution

Claimed losses, meaning

Disposal of a right to profits

Double counting prevention

Film-related loss, meaning

Generally

Key conditions

Film partnerships

Film trades

Interest relief restriction

Loss relief

Foreign income

Former partner's liability

Forming a

Gambling club, undeclared receipts

General provision

General provisions

Generally

Goods taken by partner, output tax

Goodwill

Goodwill and taper relief

Goodwill, transfer of business as going concern

Group relief for SDLT and stamp duty

Husband and wife

Husband and wife, registration

Jointly letting garages

Partnership or sole traders

Income

Allocation of trading profits or losses

Generally

Income profit-sharing ratios

Incorporation relief

Claims

Conditions

Generally

Relevant time

Indicia of

Indirect partner

Notional trade and business

Individual partners

Information and inspection powers

Inheritance tax

Agricultural property relief

Charging provisions

Input tax deduction

Acquisition of a portion of the client base of the partnership

Contribution of client base free of charge to a new partnership

Dissolution of a partnership

Payment of input tax

Insolvency, returns

Interest on capital

Interest on loans to purchase land, relief

Interests

Assets basis

CGT purposes

Earnings basis

Generally

IHT purposes

Limited liability partnerships

Package valuation

Intermediaries as

Interpretation

Arrangements

Connected persons

Market value of lease

Partnership property

Partnership share

Transfer of chargeable interest from partnership

Transfer of chargeable interest to partnership

Transfer of interest in partnership

IR35 rules

Jersey, UK resident partner exempt from UK tax

Joining partners

Joint hearing of appeals

Judicial review challenging legality of PPNs

Late appeal against assessment, Taxes Management Act 1970, s. 49

Late elections

Late filing of returns

Leaving partners

Legal personality

Letting income

Liability for SDLT

Liability to tax

Licence-related losses

Agreement related to the licence

Calculation of income chargeable to tax

Chargeable event

Disposal of the licence, meaning

Generally

Licence, meaning

Non-active partner, meaning

Profits relating to the licence, meaning

Relevant disposal

Licence-related trading losses

Calculation of amount of income treated as received

Charge to tax

Disposal of the licence, meaning

Exit charge

Interpretation

Treated as receiving income

LIFFE locals

Limited

Limited liability

Conditions of new rules

Tantamount to employment

Two aspects of partnership tax rules

Limited liability partnerships

Limited partners

Limited partnerships

Limited, unit trust scheme

Lloyd's

Loan relationships

Capital contributions, payments in return for

Change of partnership shares

Deeply discounted securities, partners' shares

Determination of credits and debits

Exchange gains and losses

Fair value accounting

Generally

Lending between partners and partnership

Loan to invest in partnership

Loan to invest in, interest relief

Loans to invest in, interest relief

Eligibility for

Film partnerships

Generally

Successions

Local authorities and partnership programmes

Loss relief restriction

Anti-avoidance rules

Capital gains relief

Contribution to the firm, meaning

Exclusion of amounts in calculating contributions

Films

Firm, meaning

Generally

Limited liability partnerships

Limited partners

Non-active partners

Recovery of excess relief

Sideways relief, meaning

Transitional provisions

Unrelieved losses brought forward

Losses

Losses on miscellaneous transactions

Lump sums

Managed service companies

Market value of lease

Meaning

Mergers and demergers

Mergers of

Mixed partnerships

National Insurance contributions

No VAT grouping

Nominee directors

Non-active partners

Non-active partners, restriction of loss and interest relief

Definitions

Generally

Unrelieved losses brought forward

Non-active partners, restriction on reliefs

Amount of reliefs not to exceed cap

Contribution to the firm, meaning

Early tax years

Exclusion of amounts in calculating contribution

Film exploitation

Licence-related losses

Loans

Non-active partner, meaning

Pre-10 February 2004 events

Recovery of excess relief

Unrelieved losses brought forward

Non-resident partners

Notices served on partnership

Notifiable transactions

Notional business or trade

Basis periods

Commencement or cessation

Overlap profits

Nursing home, additional tax for undisclosed business receipts

Option to tax

Generally

Transfer of an interest in land

Ordinary transactions

Other interpretation provisions

Overpaid tax, recovery of

Overview

P, meaning

Partner capacity

Partner exempt from UK tax on overseas earnings

Partner holding an office

Partner payment notices (PPNs)

Generally

Issued in breach of general public law and unlawful interference with taxpayers' human rights

Judicial review challenging legality of

Partner's private petrol

– see Road fuel

Partner's VAT liability

Partners' removal expenses

Partners' share of income

Allocation of firm's profits and losses between partners

Calculation of firm's profits and losses

Double taxation relief

Generally

Non-trading income

Notional business carried on by partner

Notional trade carried on by partner

Remittance basis

Partners' withdrawal from firm, payments made on

Partners, responsibility of

Generally

Joint and several liability

Nominated partners

Partnership business, division of

Partnership interests held by trustees

Partnership property

Generally

Market rent lease

Partnership return

Generally

Submitted late

Partnership share

Partnership trade regarded as single trade

Partnerships other than property-investment partnerships

Patent rights, profits from exploitation of

Patent rights, sale of

Cessation of trade

Changes of membership of firm

Generally

Patents

Patents, spreading rules

Payments between partners outside the accounts

Penalties

Acceptance of Pt. 36 offer

Assessments for PAYE and National Insurance contributions (NICs)

Determination following settlement by agreement of amendment of returns

Entitlement to charge under TMA70, s. 95

Late submission of partnership tax return

Penalties charged, upheld

Penalties for errors

Penalty assessment for dishonest evasion

Personal reliefs

Personal service companies

Personality

Persons leaving the partnership

Conduct notices

Defeat notices

Monitoring notices

Plant and machinery allowances

Effect of partnership changes

Generally

Leasing business, restriction on use of losses

Qualifying activities

Using property of partner

Post-transaction consideration

Effect of para. 17A

FA 2005 measure

Removal of double charge

Transition in Scotland to the Land and Buildings Transaction Tax

Pre-registration input tax, investment costs and invoices

Principle of continuity, partnership statements

Private tuition

Profit share agreement amounting to

Profits and assets test

Profits and losses

Partnership returns made final for tax purposes

Property business

Adjustments on change of basis

Generally

Property income

Property losses

Property partnerships

Disretionary trust income

Restriction of relief for investment loan interest

Tax reduction for individuals

Tax reduction for non-deductible loan interest

Property-investment partnerships

Rebates of management and performance fees, deductibility

Records, negligence

Recovery of excess loss relief

Calculation of amount treated as received

Charge to tax

Income treated as arising when chargeable event occurs

Overview

Post-1 December 2004 loss, meaning

Total amount of trade losses claimed

Recovery of excess relief

Amount of income treated as received

Amount of trade losses claimed, meaning

Chargeable events

Conditions for charge

Generally

Individual's contribution to the firm, meaning

Reclaimed relief, meaning

Recovery of VAT

Redemption of deductions

Registration

Changes in circumstances, notifying HMRC

Consideration for VATable services/distribution of partners' funds

Generally

Grouping

In name of firm, liability for VAT

Joining partnership, capital paid

Limited liability partnerships

Limited partnerships

No grouping by partners

Notification to commissioners

Partner's VAT liability

Partnership as separate person

Property business: joint venture by partner

Repayment of overpaid VAT

Representation

Scotland

Service of notices

Solicitors

– see Solicitors

Transfers of interests

Registration forms CIS304

Registration, entitlement

Relevant corporate partner, meaning

Relevant period, meaning

Reliefs and exemptions

Repayment supplement

Replacement of business assets

Representative partners

Residence

Chargeable gains

Residency issues

Responsible partners

Restriction of relief for investment loan interest

Restriction on disposals

Restrictions

Retired partner retaining interest in, business property relief

Retirement annuities

Retiring partner, entitlement to share of VAT repayment

Returns

Amendment of

Correction by HMRC

Enquiries

– see Enquiries

Failure to make

Filing dates

Generally

Power to enquire into

Statement inclusion

Withdrawal of notice by HMRC

Road fuel for private use, value of supply

Salaried partners

Sale and leaseback of films

Partners claiming losses under film acquisition relief provisions in Income Tax (Trading and Other Income) Act 2005, s. 130–140

Schedule 15, remaining provisions of

Application of stamp duty on transfers of partnership interests

Charging provisions

Exemptions and reliefs, application of

Interests held by trustees

Interpretation

Scotland

Accrued income scheme

Chargeable transfer

Scotland, deposit-takers deduction of tax at source

Self-assessment

Self-assessment returns

Amendment of

Error or mistake in statement

Generally

Incorrect

Penalties

Statement to be included

Separate registrations

Generally

Limited partnerships

Settlement provisions

– see Settlements

Settlements

– see Settlements

Share incentive plans

Shares acquired in stages

Sleeping business partners

Sole trader becoming

Sole trader taking on partner

Specific deductions

Costs connected with capital structure of business

Deductions in relation to LLP salaried members

Expenses incurred by partners individually

Interest paid by partnership

Partner recruitment costs

Partner training costs

Partnership annuities

Payments to outgoing partners

Payments to partners

Rent

Service companies

Termination payments

Stamp duty

Group relief

Transfers of partnership interest

Stamp duty land tax

Acquisition of interest in partnership

Anti-avoidance transactions

Arrangements, meaning

Charities relief

Connected persons

Continuity

Generally

Group relief

HMRC response: arrangement, meaning

Legal personality

Liability

Manual

Market value of leases

Partnership property and partnership share, meaning

Representative partners

Responsibility of partners

Returns

– see Returns

Transactions which are not notifiable

Transfer of an interest in a partnership

Transfer of an interest in a property-investment partnership

Transfer of chargeable interest from a partnership

Transfer of chargeable interest to a partnership

Transfer of chargeable interest, withdrawal of money etc. from partnership after

Unit trust scheme

Stamp duty land tax, acquisition structured to mitigate charge

Stamp duty, transfers of partnership interests

Statement of practice D12

Disposal of partnership assets to a third party

HMRC

Revaluation of partnership assets

Stock relief, recovery

Summing up

Taper relief

Tax-generated losses

Teaching services constituting supplies by

Tonnage tax

– see Tonnage tax

Trade loss relief

Anti-avoidance provisions

Capital gains relief, meaning

Exclusion of amounts in calculating contribution, regulations

Film exploitation

Firm, meaning

Generally

Leasing plant or machinery, sideways relief restriction

Licence-related

Limited partners, restriction on reliefs

Non-active partners, restriction on reliefs

Overview

Recovery of excess relief

Sideways relief, meaning

Trading income, adjustments on change of basis

Transactions between partnership and individual partners

Transfer of a business to a company

Transfer of chargeable interest from partnership

Generally

Interpretation

Transfer of chargeable interest to partnership

Charging formula

Generally

Interpretation

Transfer of interest in partnership

Generally

Interpretation

Transfer pricing

– see also Transfer pricing

Generally

Transfers

Partnership interests/contribution of property to newly formed partnership

Share in partnership: payments received for non-supplies

Transfers between persons

Transfers between persons not at arm's length

Transfers of relief within

Application

Arrangements, effects of

Interpretation

Non-trading profits and losses

Restrictions on use of reliefs

Transfers under FA 2003, Sch. 15, para. 36(a)

Partnership share

Turnover test threshold

Types of partner

UK partnership registering as Jersey limited partnership, tax treatment

Understated profits for the year

Unit trust schemes, limited partnerships

Untaxed allowances received

Valuation basis

Valuation of partner's share

Value added tax

Registration

Taxable person

Value of partner's share

VAT penalties

Civil fraud for partners

Inaccurate information

Venture capital investment partnerships, gains of insurance company

Verification

View of profit, persons carrying on a business

Activity of partners, degree of

Business in common

Business, meaning

No partnership

With a view to profit

Voting rights test

Wholly and exclusively incurred expenditure

Food and drink/overnight accommodation/hiring of room

LLP's trade or of individual member's notional trade

Relocation expenses

Winding up

Capital gains tax

Income tax