Partnership foreign income and tax paid
Owner-Managed Businesses
Guidance
This guidance note outlines the rules which apply when a partner in a UK partnership is allocated overseas income or profits.
For a discussion of the treatment of income with a UK source, see the Taxation of partnership trading profits and Taxation of other income of a partnership guidance notes. Special rules apply to those partners who access the remittance basis, see the Remittance basis ― overview guidance note.
There are many different sources of overseas income and profits, and the provisions can be complex. This guidance note is only a summary of the rules.
The taxation of UK resident partners in a partnership controlled overseas is outside the scope of this guidance note but more details can be found in Ray: Partnerships, Chapters 16 and 17. Some of the issues are also covered in INTM163130 and guidance is also provided by HMRC Helpsheet HS380.
Overseas income of individual partners
UK resident individuals are taxable on their worldwide income. This includes:
- •
trading income (ITTOIA 2005, s 6)
- •
property income (ITTOIA 2005, s 269)
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