{"corpusVersion":"2026-07-28.2","exampleProfile":{"archetypeIds":["archetype-gb-llp"],"asOf":"2026-07-28","assertions":[{"basis":"The LLP is incorporated under the 2000 Act.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2001-04-06","effectiveTo":null,"scope":{"activityOrContext":"LLP incorporation and separate personality","jurisdiction":"Great Britain","ruleset":"Limited Liability Partnerships Act 2000 section 1","subjectRef":"gb-llp","taxOrRegime":"General law"},"sourceIds":["src-llp-act-2000-s1"],"status":"established"},{"basis":"The synthetic facts state a business carried on with a view to profit.","classificationId":"attribution:member-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member A's share of the consulting business profits","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"Income Tax on LLP profits"},"sourceIds":["src-hmrc-pm131450"],"status":"conditional"},{"basis":"The salaried-member overlay does not change the amount of member B's chargeable LLP profit share.","classificationId":"attribution:member-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's chargeable share of the consulting business profits","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 sections 863 and 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-b","taxOrRegime":"Income Tax on LLP profits"},"sourceIds":["src-hmrc-pm131450"],"status":"conditional"},{"basis":"The example concerns registered members acting in the LLP business.","classificationId":"capacity:partner-or-member","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Member A acting in the consulting business","jurisdiction":"Great Britain","ruleset":"LLP Act 2000 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"LLP membership"},"sourceIds":["src-hmrc-pm131450"],"status":"established"},{"basis":"The synthetic example states that member B meets all salaried-member conditions; this is a tax and National Insurance overlay, not a change to profit attribution.","classificationId":"capacity:salaried-llp-member","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's reward for services as an LLP member","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-b","taxOrRegime":"PAYE and Class 1 National Insurance"},"sourceIds":["src-hmrc-pm131450"],"status":"established"},{"basis":"Incorporation and a UK office do not settle every member or treaty residence question.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":"2027-04-05","scope":{"activityOrContext":"Member A's 2026-27 tax year","jurisdiction":"United Kingdom","ruleset":"UK domestic residence rules as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"Income Tax residence"},"sourceIds":["src-hmrc-rdrm20060"],"status":"unknown"},{"basis":"Incorporation supplies the company-registry identity.","classificationId":"registration:companies-house","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2001-04-06","effectiveTo":null,"scope":{"activityOrContext":"LLP incorporation","jurisdiction":"Great Britain","ruleset":"Limited Liability Partnerships Act 2000","subjectRef":"gb-llp","taxOrRegime":"Companies House registration"},"sourceIds":["src-llp-act-2000-s1"],"status":"established"},{"basis":"The synthetic subjects are registered LLP members.","classificationId":"control:member","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Registered membership in the synthetic LLP","jurisdiction":"Great Britain","ruleset":"LLP Act 2000 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"LLP membership"},"sourceIds":["src-hmrc-pm131450"],"status":"established"},{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:financial-institution","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:active-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:passive-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The LLP computes and reports partnership results while members are normally charged.","classificationId":"obligation:filing-unit-not-chargeable","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Consulting business profit computation and return","jurisdiction":"United Kingdom","ruleset":"HMRC partnership-tax guidance as at 2026-07-28","subjectRef":"gb-llp","taxOrRegime":"Partnership return"},"sourceIds":["src-hmrc-pm136000"],"status":"established"},{"basis":"The LLP operates PAYE and Class 1 National Insurance for member B's reward without changing the member-level attribution of chargeable LLP profits.","classificationId":"obligation:employer-withholder","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's salaried-member reward","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"gb-llp","taxOrRegime":"PAYE and Class 1 National Insurance"},"sourceIds":["src-hmrc-pm131450"],"status":"established"}],"id":"example-trading-llp","jurisdiction":"Great Britain","label":"Great Britain consulting LLP with two differently treated members","notDetermined":["Member profit shares or liabilities.","Foreign, treaty, CRS, VAT or payroll treatment."],"reviewTriggers":["Check whether each member falls within salaried-members rules.","Classify the LLP separately in every foreign jurisdiction involved.","Resolve VAT, PAYE and member residence independently."],"subjects":[{"id":"gb-llp","kind":"limited-liability-partnership","label":"Synthetic Great Britain LLP"},{"id":"llp-member-a","kind":"natural-person-member","label":"Synthetic LLP member A"},{"id":"llp-member-b","kind":"natural-person-member","label":"Synthetic salaried LLP member B"}],"summary":"A synthetic Great Britain LLP carries on consulting for profit. Both members receive profit shares; one also meets all salaried-member conditions for the PAYE and Class 1 National Insurance overlay."},"interpretation":{"boundary":{"filingOrSubmission":false,"legalAdvice":false,"personalFactsAccepted":false,"singleLabelSufficient":false,"syntheticExample":true},"example":{"archetypeIds":["archetype-gb-llp"],"asOf":"2026-07-28","id":"example-trading-llp","jurisdiction":"Great Britain","label":"Great Britain consulting LLP with two differently treated members","subjects":[{"id":"gb-llp","kind":"limited-liability-partnership","label":"Synthetic Great Britain LLP"},{"id":"llp-member-a","kind":"natural-person-member","label":"Synthetic LLP member A"},{"id":"llp-member-b","kind":"natural-person-member","label":"Synthetic salaried LLP member B"}],"summary":"A synthetic Great Britain LLP carries on consulting for profit. Both members receive profit shares; one also meets all salaried-member conditions for the PAYE and Class 1 National Insurance overlay."},"identityVector":[{"assertions":[{"basis":"The LLP is incorporated under the 2000 Act.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2001-04-06","effectiveTo":null,"scope":{"activityOrContext":"LLP incorporation and separate personality","jurisdiction":"Great Britain","ruleset":"Limited Liability Partnerships Act 2000 section 1","subjectRef":"gb-llp","taxOrRegime":"General law"},"sourceIds":["src-llp-act-2000-s1"],"status":"established"}],"dimensionId":"legal-existence","dimensionLabel":"Legal existence and form"},{"assertions":[{"basis":"The synthetic facts state a business carried on with a view to profit.","classificationId":"attribution:member-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member A's share of the consulting business profits","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"Income Tax on LLP profits"},"sourceIds":["src-hmrc-pm131450"],"status":"conditional"},{"basis":"The salaried-member overlay does not change the amount of member B's chargeable LLP profit share.","classificationId":"attribution:member-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's chargeable share of the consulting business profits","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 sections 863 and 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-b","taxOrRegime":"Income Tax on LLP profits"},"sourceIds":["src-hmrc-pm131450"],"status":"conditional"}],"dimensionId":"tax-attribution","dimensionLabel":"Tax attribution and charge"},{"assertions":[{"basis":"The example concerns registered members acting in the LLP business.","classificationId":"capacity:partner-or-member","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Member A acting in the consulting business","jurisdiction":"Great Britain","ruleset":"LLP Act 2000 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"LLP membership"},"sourceIds":["src-hmrc-pm131450"],"status":"established"},{"basis":"The synthetic example states that member B meets all salaried-member conditions; this is a tax and National Insurance overlay, not a change to profit attribution.","classificationId":"capacity:salaried-llp-member","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's reward for services as an LLP member","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-b","taxOrRegime":"PAYE and Class 1 National Insurance"},"sourceIds":["src-hmrc-pm131450"],"status":"established"}],"dimensionId":"capacity-activity","dimensionLabel":"Capacity and activity"},{"assertions":[{"basis":"Incorporation and a UK office do not settle every member or treaty residence question.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":"2027-04-05","scope":{"activityOrContext":"Member A's 2026-27 tax year","jurisdiction":"United Kingdom","ruleset":"UK domestic residence rules as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"Income Tax residence"},"sourceIds":["src-hmrc-rdrm20060"],"status":"unknown"}],"dimensionId":"residence-nexus","dimensionLabel":"Residence and territorial nexus"},{"assertions":[{"basis":"Incorporation supplies the company-registry identity.","classificationId":"registration:companies-house","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2001-04-06","effectiveTo":null,"scope":{"activityOrContext":"LLP incorporation","jurisdiction":"Great Britain","ruleset":"Limited Liability Partnerships Act 2000","subjectRef":"gb-llp","taxOrRegime":"Companies House registration"},"sourceIds":["src-llp-act-2000-s1"],"status":"established"}],"dimensionId":"registration-grouping","dimensionLabel":"Registration, election and grouping"},{"assertions":[{"basis":"The synthetic subjects are registered LLP members.","classificationId":"control:member","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Registered membership in the synthetic LLP","jurisdiction":"Great Britain","ruleset":"LLP Act 2000 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"LLP membership"},"sourceIds":["src-hmrc-pm131450"],"status":"established"}],"dimensionId":"ownership-control","dimensionLabel":"Ownership, control and benefit"},{"assertions":[{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:active-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:financial-institution","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.","classificationId":"reporting:passive-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"gb-llp","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"}],"dimensionId":"reporting-classification","dimensionLabel":"Reporting classification"},{"assertions":[{"basis":"The LLP operates PAYE and Class 1 National Insurance for member B's reward without changing the member-level attribution of chargeable LLP profits.","classificationId":"obligation:employer-withholder","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Member B's salaried-member reward","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28","subjectRef":"gb-llp","taxOrRegime":"PAYE and Class 1 National Insurance"},"sourceIds":["src-hmrc-pm131450"],"status":"established"},{"basis":"The LLP computes and reports partnership results while members are normally charged.","classificationId":"obligation:filing-unit-not-chargeable","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Consulting business profit computation and return","jurisdiction":"United Kingdom","ruleset":"HMRC partnership-tax guidance as at 2026-07-28","subjectRef":"gb-llp","taxOrRegime":"Partnership return"},"sourceIds":["src-hmrc-pm136000"],"status":"established"}],"dimensionId":"obligation-role","dimensionLabel":"Filing, payment and withholding role"}],"notDetermined":["Member profit shares or liabilities.","Foreign, treaty, CRS, VAT or payroll treatment."],"overlaps":[{"dangerousShortcut":"Calling the LLP a company taxpayer because it is incorporated, or calling it legally unincorporated because it is transparent.","id":"overlap-body-corporate-and-member-taxation","label":"Separate body corporate, member-level taxation","matchedAssertions":{"llp-body":{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","scope":{"activityOrContext":"LLP incorporation and separate personality","jurisdiction":"Great Britain","ruleset":"Limited Liability Partnerships Act 2000 section 1","subjectRef":"gb-llp","taxOrRegime":"General law"},"status":"established"},"members-charged":{"classificationId":"attribution:member-level","dimensionId":"tax-attribution","scope":{"activityOrContext":"Member A's share of the consulting business profits","jurisdiction":"United Kingdom","ruleset":"ITTOIA 2005 section 863 and HMRC PM131450 as at 2026-07-28","subjectRef":"llp-member-a","taxOrRegime":"Income Tax on LLP profits"},"status":"conditional"}},"meaning":"The LLP owns, contracts and files as a body corporate while the relevant income and gains are normally attributed to members.","sourceIds":["src-hmrc-hybrid-entities","src-hmrc-pm131450","src-llp-act-2000-s1"],"status":"conditional"}],"review":{"conflictingDimensionIds":[],"inactiveAssertionIds":[],"reasons":["A member may fall within salaried-members rules.","Another jurisdiction classifies the LLP.","Assertion reporting-classification:reporting:active-nfe@gb-llp|United Kingdom|Common Reporting Standard|Hypothetical financial account|OECD CRS 2025 subject to UK implementation is unknown.","Assertion reporting-classification:reporting:financial-institution@gb-llp|United Kingdom|Common Reporting Standard|Hypothetical financial account|OECD CRS 2025 subject to UK implementation is unknown.","Assertion reporting-classification:reporting:passive-nfe@gb-llp|United Kingdom|Common Reporting Standard|Hypothetical financial account|OECD CRS 2025 subject to UK implementation is unknown.","Assertion residence-nexus:nexus:uk-domestic-resident@llp-member-a|United Kingdom|Income Tax residence|Member A's 2026-27 tax year|UK domestic residence rules as at 2026-07-28 is unknown.","Check whether each member falls within salaried-members rules.","Classify the LLP separately in every foreign jurisdiction involved.","No active established, conditional, disputed or not-applicable assertion covers reporting-classification.","No active established, conditional, disputed or not-applicable assertion covers residence-nexus.","Non-profit activity, winding up or temporary cessation.","Overlap overlap-body-corporate-and-member-taxation is conditional on at least one assertion.","Resolve VAT, PAYE and member residence independently."],"status":"needs-review"},"schema":"taxsorted.tax-identity-interpretation/1","sourceIds":["src-hmrc-hybrid-entities","src-hmrc-pm131450","src-hmrc-pm136000","src-hmrc-rdrm20060","src-llp-act-2000-s1","src-oecd-crs-2025"],"unresolvedDimensionIds":["residence-nexus","reporting-classification"]},"schema":"taxsorted.uk.tax-identity-example-detail/1","sources":[{"authorityLevel":"legislation","id":"src-llp-act-2000-s1","jurisdiction":"Great Britain at creation; later extended to Northern Ireland","limitations":["The Act's general-law personality does not make an LLP a company taxpayer for every tax.","Northern Ireland first used separate 2002 legislation; Companies Act 2006 section 1286 later extended the Great Britain enactments and ended the separate Act."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["The Act created the Great Britain LLP form as a body corporate with legal personality separate from its members.","The current territorial position cannot be read from the original 2000 creation event alone."],"title":"Limited Liability Partnerships Act 2000, section 1","url":"https://www.legislation.gov.uk/ukpga/2000/12/section/1"},{"authorityLevel":"official-guidance","id":"src-hmrc-pm131450","jurisdiction":"United Kingdom","limitations":["Partnership treatment still depends on the activity, period and exact tax provision; salaried-member treatment is a separate member-level payroll and National Insurance overlay."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["An LLP carrying on business with a view to profit is normally treated as a partnership for income and gains.","Members are generally charged on their shares even though the LLP is a body corporate.","The salaried-members rules can add employment treatment for PAYE and Class 1 National Insurance purposes without changing a member's chargeable profit share."],"title":"PM131450: LLP taxation","url":"https://www.gov.uk/hmrc-internal-manuals/partnership-manual/pm131450"},{"authorityLevel":"official-guidance","id":"src-hmrc-pm136000","jurisdiction":"United Kingdom","limitations":["Transparent and opaque are shorthand; charge-specific rules still control."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Partnership business profits are computed at partnership level and attributed to partners.","The partnership can still carry PAYE and VAT responsibilities."],"title":"PM136000: Taxing partnership profits","url":"https://www.gov.uk/hmrc-internal-manuals/partnership-manual/pm136000"},{"authorityLevel":"official-guidance","id":"src-hmrc-rdrm20060","jurisdiction":"United Kingdom","limitations":["Historical periods and taxes outside the changed regime require their own rules."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["From 6 April 2025, domicile as a relevant tax connecting factor was replaced by a residence-based system in the scope described by HMRC.","Nationality, residence and domicile are distinct concepts."],"title":"RDRM20060: Domicile background and the 2025 change","url":"https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm20060"},{"authorityLevel":"model-standard","id":"src-oecd-crs-2025","jurisdiction":"International","limitations":["Domestic implementation and effective dates control reporting obligations.","The 2025 consolidation includes amendments whose first exchanges are expected later."],"publisher":"OECD","retrievedAt":"2026-07-28","supports":["CRS Entity, Financial Institution, Active NFE, Passive NFE and Controlling Person are separate reporting classifications.","A trust's controlling-person roles include settlors, trustees, protectors, beneficiaries or classes and other persons exercising ultimate effective control."],"title":"Consolidated text of the Common Reporting Standard 2025","url":"https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/04/consolidated-text-of-the-common-reporting-standard-2025_e478bc04/055664b1-en.pdf"},{"authorityLevel":"official-guidance","id":"src-hmrc-hybrid-entities","jurisdiction":"United Kingdom","limitations":["Diagram notation communicates claims; it does not prove them."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A UK company can be a company where incorporated and disregarded for US tax.","A UK LLP can be transparent in the UK and treated as a corporation elsewhere.","Incorporation and tax residence belong on separate parts of a group map."],"title":"Help with sharing group structure information","url":"https://www.gov.uk/government/publications/help-with-sharing-group-structure-information-gfc17/help-with-sharing-group-structure-information"}]}