{"archetypes":[{"commonMisreadings":["Treating a business name as a company.","Assuming employee and sole-trader capacities cannot coexist.","Treating a UTR or VAT number as proof of employment status."],"dimensionHighlights":["legal:natural-person","capacity:sole-trader","attribution:subject-level","registration:self-assessment"],"id":"archetype-sole-trader","label":"UK sole trader","sourceIds":["src-hmrc-sole-trader-2026","src-govuk-employment-status","src-hmrc-vat-guide-700"],"subjectKind":"natural-person-in-business-capacity","summary":"One natural person carries on a business; the trading name does not become a second legal person.","taxRoles":[{"caveat":"The trade is a separate income source but not a separate legal person.","role":"Taxpayer and filer","subject":"The natural person","taxOrRegime":"Income Tax on trade profits"},{"caveat":"All business activities of that registered person normally sit under the registration; business purpose remains item-specific.","role":"Registrant if required or elected","subject":"The natural person acting as taxable person","taxOrRegime":"VAT"}],"territory":"United Kingdom"},{"commonMisreadings":["Calling the firm legally invisible because it files.","Calling the firm a separate company because it has a UTR or VRN.","Assuming the same partner set after a membership change."],"dimensionHighlights":["legal:unincorporated-relationship","attribution:member-level","obligation:filing-unit-not-chargeable","registration:self-assessment"],"id":"archetype-english-general-partnership","label":"English, Welsh or Northern Irish general partnership","sourceIds":["src-partnership-act-1890-s1","src-hmrc-pm120100","src-hmrc-pm136000","src-hmrc-vat-partnership-person"],"subjectKind":"unincorporated-business-relationship","summary":"The partnership relationship lacks separate general-law personality, yet tax law can treat the firm as a filing or VAT person while attributing business profits to partners.","taxRoles":[{"caveat":"The partnership computes and returns the business result.","role":"Charged on allocated shares","subject":"The partners","taxOrRegime":"Income or Corporation Tax on partnership profits"},{"caveat":"A change in partners can change the VAT person.","role":"A person for VAT purposes","subject":"The partners acting collectively","taxOrRegime":"VAT"}],"territory":"England, Wales or Northern Ireland"},{"commonMisreadings":["Applying the English legal-personality answer across the UK.","Assuming separate personality means opaque taxation."],"dimensionHighlights":["legal:separate-firm-person","attribution:member-level","obligation:filing-unit-not-chargeable"],"id":"archetype-scottish-partnership","label":"Scottish general partnership","sourceIds":["src-partnership-act-1890-s4","src-hmrc-pm120100","src-hmrc-pm136000"],"subjectKind":"separate-firm-with-member-attribution","summary":"The firm has separate legal personality, while business profits can still be attributed to partners under UK tax rules.","taxRoles":[{"caveat":"Separate Scots-law personality does not force entity-level taxation.","role":"Charged on allocated shares","subject":"The partners","taxOrRegime":"Income or Corporation Tax on partnership profits"}],"territory":"Scotland"},{"commonMisreadings":["Treating body corporate and company taxpayer as synonyms.","Calling LLP transparency unconditional.","Assuming every LLP member has the same employment or National Insurance status."],"dimensionHighlights":["legal:body-corporate","attribution:member-level","capacity:partner-or-member","registration:companies-house"],"id":"archetype-gb-llp","label":"Great Britain limited liability partnership","sourceIds":["src-llp-act-2000-s1","src-hmrc-pm131450","src-hmrc-hybrid-entities"],"subjectKind":"body-corporate-with-conditional-member-attribution","summary":"The Great Britain LLP form created by the 2000 Act is a separate body corporate in general law but is normally treated like a partnership for income and gains when it carries on business with a view to profit.","taxRoles":[{"caveat":"Business-with-a-view-to-profit and winding-up exceptions need separate checks.","role":"Normally charged on their shares","subject":"The members","taxOrRegime":"Income and gains"},{"caveat":"The overlay does not change the amount of that member's chargeable share of LLP profits.","role":"Employment-treatment overlay for the member's reward","subject":"An individual member meeting all salaried-member conditions","taxOrRegime":"PAYE and Class 1 National Insurance"},{"caveat":"A company-law filing role does not make it a company for the partnership tax provisions.","role":"Registered body filing accounts and notices","subject":"The LLP","taxOrRegime":"Company-law filings"}],"territory":"England, Wales and Scotland"},{"commonMisreadings":["Projecting the original Great Britain creation event backwards into Northern Ireland.","Treating the repealed 2002 Act as current standalone law.","Treating body-corporate status as entity-level taxation."],"dimensionHighlights":["legal:body-corporate","attribution:member-level","capacity:partner-or-member","registration:companies-house"],"id":"archetype-ni-llp","label":"Northern Ireland limited liability partnership lineage","sourceIds":["src-ni-llp-act-2002-s1","src-companies-act-2006-s1286","src-hmrc-pm131450"],"subjectKind":"body-corporate-with-territorial-lineage","summary":"Northern Ireland created a separate LLP form in 2002; Companies Act 2006 section 1286 later extended the Great Britain enactments to Northern Ireland and ended the separate Act.","taxRoles":[{"caveat":"Formation and transaction dates decide whether the separate 2002 Act or the later UK-wide framework is the relevant origin source.","role":"Body corporate under the legislation effective for its period","subject":"The Northern Ireland LLP","taxOrRegime":"Legal-form history"},{"caveat":"The same business-with-a-view-to-profit and exception checks remain necessary.","role":"Normally charged on their shares","subject":"The members","taxOrRegime":"Income and gains"}],"territory":"Northern Ireland"},{"commonMisreadings":["Treating director, shareholder and company as one taxpayer.","Treating registered office as proof of actual management.","Assuming another jurisdiction follows the UK classification."],"dimensionHighlights":["legal:body-corporate","attribution:subject-level","capacity:company-trader","registration:companies-house","nexus:uk-domestic-resident"],"id":"archetype-private-company","label":"UK private limited company","sourceIds":["src-companies-act-2006-s16","src-hmrc-intm120040","src-hmrc-intm120180"],"subjectKind":"incorporated-company","summary":"The company is a body corporate separate from shareholders and directors, with tax residence and activity tested on their own dimensions.","taxRoles":[{"caveat":"Residence, source, group rules and distributions can create further classifications.","role":"Taxpayer on its profits and gains","subject":"The company","taxOrRegime":"Corporation Tax"}],"territory":"United Kingdom"},{"commonMisreadings":["Treating charity as a base legal form.","Treating recognition as a blanket tax exemption.","Treating members, trustees or directors as beneficial owners of charitable assets."],"dimensionHighlights":["legal:body-corporate","capacity:charity","attribution:subject-level","registration:charity-and-tax-recognition"],"id":"archetype-charitable-company","label":"UK charitable company","sourceIds":["src-companies-act-2006-s16","src-finance-act-2010-charity","src-charity-tax-exemptions"],"subjectKind":"company-with-charity-status","summary":"One body can simultaneously be a company, a charity and an employer, with tax reliefs conditional on the income, activity and use of funds.","taxRoles":[{"caveat":"Trading, property, gains and application to charitable purposes must be tested under the relevant provision.","role":"Company taxpayer with conditional exemptions","subject":"The charitable company","taxOrRegime":"Corporation Tax and charity exemptions"}],"territory":"United Kingdom"},{"commonMisreadings":["Calling the trust itself a company-like legal person.","Treating legal title, beneficial interest and control as one role.","Assuming the person filing is the person strictly chargeable."],"dimensionHighlights":["legal:legal-arrangement","capacity:trustee","capacity:beneficiary","reporting:trust-roles","control:trustee-legal-title","control:beneficiary-interest"],"id":"archetype-express-trust","label":"UK express trust","sourceIds":["src-hmrc-tsem1563","src-hmrc-tsem4200","src-fatf-legal-arrangements-2024","src-oecd-crs-2025"],"subjectKind":"legal-arrangement-with-multiple-actors","summary":"A trust is a legal arrangement with settlor, trustee, beneficiary and possible protector roles; the person charged can change with the trust type and rule.","taxRoles":[{"caveat":"Whether the trust is bare is a legal and factual question.","role":"Strictly chargeable where immediate and absolute entitlement exists","subject":"The beneficiary","taxOrRegime":"Bare-trust income and gains"},{"caveat":"No generic trust-taxpayer answer is safe.","role":"Charge and administration divided by statute","subject":"Trustees, settlor or beneficiaries depending on the rule","taxOrRegime":"Other settlements"}],"territory":"United Kingdom"},{"commonMisreadings":["Calling the VAT group a new company.","Using one VAT number as proof of one beneficial owner or one corporation-tax payer.","Forgetting effective dates when membership changes."],"dimensionHighlights":["legal:tax-group-not-person","attribution:single-vat-person","registration:vat-group","control:common-control","obligation:representative-member"],"id":"archetype-vat-group","label":"UK VAT group","sourceIds":["src-hmrc-vat-groups"],"subjectKind":"tax-specific-grouping","summary":"Several eligible persons retain their legal identities while VAT treats the group through one representative member as a single taxable person.","taxRoles":[{"caveat":"Members can remain jointly and severally liable.","role":"One return and payment account","subject":"The grouped taxable person through its representative member","taxOrRegime":"VAT"},{"caveat":"VAT grouping does not merge them for other purposes.","role":"Separate legal and direct-tax subject","subject":"Each member company","taxOrRegime":"Company law and Corporation Tax"}],"territory":"United Kingdom"},{"commonMisreadings":["Treating branch, subsidiary, PE and VAT fixed establishment as synonyms.","Issuing residence conclusions in the branch's name.","Assuming a registered branch proves a PE or vice versa."],"dimensionHighlights":["legal:non-separate-presence","nexus:permanent-establishment","attribution:main-entity-with-presence","obligation:main-entity-pe-return"],"id":"archetype-branch-pe","label":"Foreign company with a UK branch or permanent establishment","sourceIds":["src-hmrc-branch-pe","src-oecd-model-2017","src-hmrc-vat-fixed-establishment"],"subjectKind":"non-separate-presence-with-local-nexus","summary":"The foreign company remains the legal person, while a UK presence can create a local charge and profit-attribution exercise.","taxRoles":[{"caveat":"The existence of the PE and the amount attributable to it are separate questions.","role":"Taxpayer on attributable UK profits","subject":"The non-resident company","taxOrRegime":"Corporation Tax on UK permanent-establishment profits"}],"territory":"United Kingdom and another jurisdiction"}],"dimensions":[{"cardinality":"one","classificationValues":[{"doesNotMean":"One unchanging tax capacity or one source of income.","id":"legal:natural-person","label":"Natural person","meaning":"A human legal person.","sourceIds":["src-hmrc-sole-trader-2026"]},{"doesNotMean":"Opaque or company-taxed in every jurisdiction and charge.","id":"legal:body-corporate","label":"Body corporate","meaning":"A separate incorporated legal person.","sourceIds":["src-companies-act-2006-s16","src-llp-act-2000-s1","src-ni-llp-act-2002-s1"]},{"doesNotMean":"Invisible to tax administration or incapable of filing.","id":"legal:unincorporated-relationship","label":"Unincorporated relationship","meaning":"A relationship such as an English general partnership, without separate general-law personality.","sourceIds":["src-partnership-act-1890-s1","src-hmrc-pm120100"]},{"doesNotMean":"Entity-level taxation of its business profits.","id":"legal:separate-firm-person","label":"Separate firm person","meaning":"A firm with distinct legal personality, such as a Scottish partnership.","sourceIds":["src-partnership-act-1890-s4","src-hmrc-pm120100"]},{"doesNotMean":"One universal trust taxpayer.","id":"legal:legal-arrangement","label":"Legal arrangement","meaning":"A relationship governing property and roles, such as a trust.","sourceIds":["src-fatf-legal-arrangements-2024","src-hmrc-tsem10020"]},{"doesNotMean":"No local taxing nexus.","id":"legal:non-separate-presence","label":"Non-separate presence","meaning":"A branch or business presence that is part of another person.","sourceIds":["src-hmrc-branch-pe"]},{"doesNotMean":"The member entities disappear for other law or taxes.","id":"legal:tax-group-not-person","label":"Tax group, not a new legal person","meaning":"A grouping that a tax regime treats together.","sourceIds":["src-hmrc-vat-groups"]}],"id":"legal-existence","label":"Legal existence and form","meaning":"Start with the natural person, body, relationship or arrangement created by general law. This is the legal shell, not the whole tax answer.","origin":"Company, partnership, trust and association law creates or recognises these categories. Tax law can borrow, override or ignore them for a stated purpose.","question":"What exists under the governing private law?","reviewWhen":["The subject is formed outside the jurisdiction applying the tax.","The governing documents or formation status are unavailable.","A partnership is connected with Scotland.","A label such as company, foundation, association or trust has been translated from another legal system."],"sourceIds":["src-partnership-act-1890-s1","src-partnership-act-1890-s4","src-companies-act-2006-s16","src-llp-act-2000-s1","src-ni-llp-act-2002-s1","src-companies-act-2006-s1286","src-fatf-legal-arrangements-2024","src-hmrc-tsem10020","src-hmrc-sole-trader-2026","src-hmrc-branch-pe","src-hmrc-vat-groups","src-hmrc-pm120100"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"The subject has one treatment for every item, or that owners have no separate distribution, gain, payroll or reporting consequences.","id":"attribution:subject-level","label":"Scoped subject charge","meaning":"The scoped natural person or legal entity is charged on the relevant item in its own name.","sourceIds":["src-hmrc-intm180010","src-charity-tax-exemptions"]},{"doesNotMean":"The partnership has no computation, return, VAT or PAYE role.","id":"attribution:member-level","label":"Member-level attribution","meaning":"Members or partners are charged on attributed shares.","sourceIds":["src-hmrc-pm131450","src-hmrc-pm136000"]},{"doesNotMean":"The legal entity disappears, another jurisdiction follows the look-through, or every tax uses the same treatment.","id":"attribution:owner-level","label":"Owner-level attribution","meaning":"The stated regime looks through a separate legal form and charges its owner on the relevant item.","sourceIds":["src-irs-entity-classification-2026","src-hmrc-hybrid-entities"]},{"doesNotMean":"Every trust is bare or every trust item follows this rule.","id":"attribution:beneficiary-level","label":"Beneficiary-level attribution","meaning":"The beneficiary is charged on the relevant trust income or gains.","sourceIds":["src-hmrc-tsem1563"]},{"doesNotMean":"Trustees beneficially own the property.","id":"attribution:trustee-level","label":"Trustee-level charge","meaning":"Trustees are the persons charged or assessed for the stated rule.","sourceIds":["src-hmrc-tsem10020"]},{"doesNotMean":"The settlor is always charged on trust income.","id":"attribution:settlor-level","label":"Settlor attribution","meaning":"A settlement rule attributes the item to the settlor.","sourceIds":["src-hmrc-tsem4200"]},{"doesNotMean":"One company for corporation tax or company law.","id":"attribution:single-vat-person","label":"Single VAT taxable person","meaning":"Several members are treated together for VAT through a representative member.","sourceIds":["src-hmrc-vat-groups"]},{"doesNotMean":"The presence is a separate resident legal person.","id":"attribution:main-entity-with-presence","label":"Main entity with attributed presence","meaning":"The main person remains the taxpayer while profits are attributed to a branch or permanent establishment.","sourceIds":["src-hmrc-branch-pe","src-oecd-model-2017"]}],"id":"tax-attribution","label":"Tax attribution and charge","meaning":"Tax can charge the legal person, look through to members, attribute to a beneficiary or settlor, or use a representative member.","origin":"Each charging provision defines or implies its own taxpayer and attribution rule. Transparent and opaque are convenient descriptions, not universal properties.","question":"For this tax and item, who is treated as earning, owning or disposing?","reviewWhen":["A transparent or opaque label is being reused across taxes.","An LLP is not carrying on a business with a view to profit or is winding up.","A trust type or entitlement is unclear.","Two jurisdictions classify the same body differently."],"sourceIds":["src-hmrc-intm180010","src-hmrc-pm131450","src-hmrc-pm136000","src-irs-entity-classification-2026","src-hmrc-hybrid-entities","src-hmrc-tsem1563","src-hmrc-tsem10020","src-hmrc-tsem4200","src-hmrc-vat-groups","src-hmrc-branch-pe","src-oecd-model-2017","src-charity-tax-exemptions"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"Unable to carry on a separate trade.","id":"capacity:employee","label":"Employee","meaning":"Acting under an employment relationship for the stated engagement.","sourceIds":["src-govuk-employment-status","src-hmrc-pm131450"]},{"doesNotMean":"A separate legal person called the business.","id":"capacity:sole-trader","label":"Sole trader","meaning":"A natural person carrying on business on their own account.","sourceIds":["src-hmrc-sole-trader-2026"]},{"doesNotMean":"Employment or self-employment status is settled for every rule.","id":"capacity:partner-or-member","label":"Partner or LLP member","meaning":"Acting as a participant in the partnership business.","sourceIds":["src-hmrc-pm131450","src-hmrc-pm136000"]},{"doesNotMean":"The member stops being a member or their chargeable share of LLP profits changes.","id":"capacity:salaried-llp-member","label":"Salaried LLP member for tax and National Insurance","meaning":"An individual LLP member meeting all salaried-member conditions is treated like an employee for the reward, PAYE and Class 1 National Insurance rules.","sourceIds":["src-hmrc-pm131450"]},{"doesNotMean":"Every receipt belongs to the trade or every director acts personally.","id":"capacity:company-trader","label":"Company carrying on activity","meaning":"The body corporate carries on the stated trade or business.","sourceIds":["src-charity-tax-exemptions"]},{"doesNotMean":"All activities and income are exempt.","id":"capacity:charity","label":"Charitable capacity","meaning":"The subject is recognised and acts for charitable purposes within the stated rule.","sourceIds":["src-finance-act-2010-charity","src-charity-tax-exemptions"]},{"doesNotMean":"Beneficial ownership.","id":"capacity:trustee","label":"Trustee","meaning":"Holding or administering property under trust duties.","sourceIds":["src-hmrc-tsem1563","src-fatf-legal-arrangements-2024"]},{"doesNotMean":"Control, legal title or present tax liability in every trust.","id":"capacity:beneficiary","label":"Beneficiary","meaning":"Holding a beneficial interest or entitlement.","sourceIds":["src-hmrc-tsem1563","src-fatf-legal-arrangements-2024"]},{"doesNotMean":"Self-employed for every direct-tax or employment-law rule.","id":"capacity:independent-economic-actor","label":"Independent economic actor","meaning":"Independently carrying on economic activity for the VAT rule.","sourceIds":["src-eu-vat-directive","src-hmrc-vat-guide-700"]}],"id":"capacity-activity","label":"Capacity and activity","meaning":"The same person can be an employee, sole trader, landlord, partner, trustee, director, employer and investor at the same time.","origin":"Charging rules and case law classify an activity or relationship, not a whole human being for all purposes.","question":"In what role is the subject acting for this item or engagement?","reviewWhen":["One person has more than one income source or engagement.","Employment and self-employment labels are inferred from a job title.","A director's personal and company capacities are mixed.","A charity carries on trading or investment activity."],"sourceIds":["src-hmrc-sole-trader-2026","src-govuk-employment-status","src-hmrc-vat-guide-700","src-eu-vat-directive","src-hmrc-pm131450","src-hmrc-pm136000","src-charity-tax-exemptions","src-finance-act-2010-charity","src-hmrc-tsem1563","src-fatf-legal-arrangements-2024"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"Exclusive treaty residence or residence for every reporting regime.","id":"nexus:uk-domestic-resident","label":"UK domestic resident","meaning":"UK domestic law treats the subject as resident for the stated tax and period.","sourceIds":["src-hmrc-intm120040","src-hmrc-rdrm20060","src-hmrc-tsem10020"]},{"doesNotMean":"The conflict has been resolved for treaty purposes.","id":"nexus:dual-domestic-residence","label":"Dual domestic residence","meaning":"More than one jurisdiction's domestic law treats the subject as resident.","sourceIds":["src-hmrc-intm120180","src-oecd-model-2017"]},{"doesNotMean":"The domestic residence claims cease to exist for all law.","id":"nexus:treaty-coordinated","label":"Treaty-coordinated residence","meaning":"An applicable treaty coordinates residence for that treaty.","sourceIds":["src-oecd-model-2017"]},{"doesNotMean":"Subsidiary, registered branch, VAT fixed establishment or separate legal person.","id":"nexus:permanent-establishment","label":"Permanent establishment","meaning":"A direct-tax business presence meeting the relevant domestic or treaty test.","sourceIds":["src-hmrc-branch-pe","src-oecd-model-2017"]},{"doesNotMean":"A VAT number alone or a direct-tax permanent establishment.","id":"nexus:vat-fixed-establishment","label":"VAT fixed establishment","meaning":"A VAT presence with the required permanence and human and technical resources for the rule.","sourceIds":["src-hmrc-vat-fixed-establishment","src-eu-vat-fixed-establishment"]},{"doesNotMean":"No local tax or reporting obligation.","id":"nexus:no-separate-residence","label":"No separate residence","meaning":"The branch, group or arrangement has no independent residence claim in the stated context.","sourceIds":["src-hmrc-branch-pe","src-hmrc-vat-groups"]}],"id":"residence-nexus","label":"Residence and territorial nexus","meaning":"Incorporation, residence, domicile, source, permanent establishment, VAT fixed establishment and payroll presence are different connecting tests.","origin":"Domestic law first makes residence and source claims; treaties coordinate only their own application; indirect-tax and payroll rules use separate connections.","question":"Which place claims residence, source or another taxing foothold for this regime?","reviewWhen":["Management, board or controlling decisions cross borders.","A remote worker, agent, office or technical resource is in another jurisdiction.","A certificate, address or VAT number is being treated as conclusive.","The actual bilateral treaty and protocol have not been read.","The period crosses a legal change, including 6 April 2025."],"sourceIds":["src-hmrc-intm120040","src-hmrc-intm120180","src-hmrc-rdrm20060","src-hmrc-tsem10020","src-hmrc-branch-pe","src-oecd-model-2017","src-hmrc-vat-fixed-establishment","src-eu-vat-fixed-establishment","src-hmrc-vat-groups"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"Tax residence, activity or beneficial ownership is proved.","id":"registration:companies-house","label":"Companies House registration","meaning":"The incorporated form is recorded by the company registrar.","sourceIds":["src-companies-act-2006-s16","src-llp-act-2000-s1"]},{"doesNotMean":"Every recorded source is current or correctly classified.","id":"registration:self-assessment","label":"Self Assessment record","meaning":"A person or filing unit has a UK Self Assessment administration record.","sourceIds":["src-hmrc-sole-trader-2026","src-hmrc-pm136000"]},{"doesNotMean":"One registration necessarily supplies the other.","id":"registration:charity-and-tax-recognition","label":"Charity and tax recognition","meaning":"Charity-law registration or recognition and HMRC tax recognition have been addressed.","sourceIds":["src-finance-act-2010-charity","src-charity-tax-exemptions"]},{"doesNotMean":"Every cost is business input tax or a fixed establishment exists.","id":"registration:vat","label":"VAT registration","meaning":"The stated taxable person is registered or required to register.","sourceIds":["src-hmrc-vat-guide-700","src-hmrc-vat-partnership-person"]},{"doesNotMean":"Corporate or direct-tax consolidation.","id":"registration:vat-group","label":"VAT group membership","meaning":"Eligible members are treated through one representative registration.","sourceIds":["src-hmrc-vat-groups"]},{"doesNotMean":"The same subject is the income-tax taxpayer on every profit.","id":"registration:payroll","label":"Payroll registration","meaning":"An employer or payer operates a payroll reporting account.","sourceIds":["src-hmrc-pm136000","src-hmrc-pm131450","src-govuk-paye-employers"]},{"doesNotMean":"The legal form changes or another jurisdiction follows the election.","id":"registration:classification-election","label":"Classification election","meaning":"An available election changes a tax classification from an effective date.","sourceIds":["src-irs-entity-classification-2026","src-us-check-box-1996"]},{"doesNotMean":"No registration duty exists.","id":"registration:none-determinative","label":"No registration is determinative","meaning":"The current evidence contains no registration that settles the classification.","sourceIds":["src-hmrc-branch-pe","src-hmrc-vat-fixed-establishment"]}],"id":"registration-grouping","label":"Registration, election and grouping","meaning":"Registration and elections can create obligations or tax-specific treatment, but a number in a database is not the underlying legal conclusion.","origin":"Company, charity and revenue registries, statutory elections and grouping rules create purpose-specific administrative identities.","question":"Which administrative accounts, elections or tax groups apply?","reviewWhen":["A legal conclusion is inferred from a UTR, VRN, EIN, TIN, company number or address.","An election date or acceptance is missing.","Group membership changed during the period.","The registered person differs from the person economically active."],"sourceIds":["src-hmrc-vat-groups","src-hmrc-vat-partnership-person","src-hmrc-vat-guide-700","src-hmrc-vat-fixed-establishment","src-hmrc-branch-pe","src-irs-entity-classification-2026","src-us-check-box-1996","src-companies-act-2006-s16","src-llp-act-2000-s1","src-hmrc-sole-trader-2026","src-charity-tax-exemptions","src-finance-act-2010-charity","src-hmrc-pm131450","src-hmrc-pm136000","src-govuk-paye-employers"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"Ultimate benefit or effective control.","id":"control:legal-owner","label":"Legal owner","meaning":"Holds legal title to the interest or property.","sourceIds":["src-fatf-legal-persons-2023","src-fatf-legal-arrangements-2024"]},{"doesNotMean":"The direct registered holder.","id":"control:beneficial-owner","label":"Beneficial owner","meaning":"The natural person who ultimately owns or benefits within the stated standard.","sourceIds":["src-fatf-legal-persons-2023"]},{"doesNotMean":"Employee, beneficial owner or controlling person in every case.","id":"control:member","label":"Member or partner","meaning":"Participates in the body or relationship under its governing rules.","sourceIds":["src-llp-act-2000-s1","src-hmrc-pm131450"]},{"doesNotMean":"The trustees own for their personal benefit.","id":"control:trustee-legal-title","label":"Trustee legal title","meaning":"Trustees hold or administer legal title under trust duties.","sourceIds":["src-fatf-legal-arrangements-2024","src-hmrc-tsem1563"]},{"doesNotMean":"Present control or a presently taxable receipt.","id":"control:beneficiary-interest","label":"Beneficiary interest","meaning":"A person or class has a beneficial interest or entitlement.","sourceIds":["src-fatf-legal-arrangements-2024","src-hmrc-tsem1563"]},{"doesNotMean":"All activities or liabilities merge.","id":"control:common-control","label":"Common control","meaning":"Members satisfy a tax regime's control connection.","sourceIds":["src-hmrc-vat-groups"]},{"doesNotMean":"They are automatically the taxpayer or guilty of wrongdoing.","id":"control:crs-controlling-person","label":"CRS controlling person","meaning":"A natural person falls within the reporting standard's controlling-person analysis.","sourceIds":["src-oecd-crs-2025","src-fatf-legal-persons-2023"]}],"id":"ownership-control","label":"Ownership, control and benefit","meaning":"Shareholder, member, legal owner, beneficial owner, trustee, beneficiary and controlling person are related roles, not synonyms.","origin":"Property and company law allocate title and formal power; anti-money-laundering and reporting rules look through to natural persons and other means of control.","question":"Who holds legal title, benefits, exercises formal power or has ultimate effective control?","reviewWhen":["Nominees, trusts, indirect chains or non-share control are present.","The registered holder is assumed to be the ultimate owner.","A senior managing official is treated as a beneficial owner without stating the fallback rule.","Private ownership information would be exposed."],"sourceIds":["src-fatf-legal-persons-2023","src-fatf-legal-arrangements-2024","src-oecd-crs-2025","src-partnership-act-1890-s4","src-hmrc-vat-groups","src-llp-act-2000-s1","src-hmrc-pm131450","src-hmrc-tsem1563"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"No business capacity.","id":"reporting:individual","label":"Individual account holder or reportable person","meaning":"The reporting regime treats the subject as an individual.","sourceIds":["src-oecd-crs-2025"]},{"doesNotMean":"A bank in ordinary speech.","id":"reporting:financial-institution","label":"Financial Institution","meaning":"The subject meets the reporting standard's financial-institution definition.","sourceIds":["src-oecd-crs-2025"]},{"doesNotMean":"Active trading for every tax.","id":"reporting:active-nfe","label":"Active NFE","meaning":"The entity meets one of the reporting standard's active non-financial entity tests.","sourceIds":["src-oecd-crs-2025"]},{"doesNotMean":"Tax avoidance or illegality.","id":"reporting:passive-nfe","label":"Passive NFE","meaning":"The entity falls within the reporting standard's passive category.","sourceIds":["src-oecd-crs-2025"]},{"doesNotMean":"Every role has the same ownership, control or tax consequence.","id":"reporting:trust-roles","label":"Trust role reporting","meaning":"Settlor, trustee, protector, beneficiary and other control roles are analysed for reporting.","sourceIds":["src-oecd-crs-2025","src-fatf-legal-arrangements-2024"]},{"doesNotMean":"Group membership is irrelevant to every report.","id":"reporting:separate-members","label":"Members remain separately classified","meaning":"A tax group does not replace each member's reporting classification.","sourceIds":["src-oecd-crs-2025","src-hmrc-vat-groups"]}],"id":"reporting-classification","label":"Reporting classification","meaning":"CRS, FATCA and other information regimes create their own entity and controlling-person buckets.","origin":"International reporting standards and their domestic implementation define purpose-specific classes distinct from income-tax treatment.","question":"How does the relevant reporting or due-diligence regime classify the subject?","reviewWhen":["Income and asset tests are missing.","A tax-transparent label is reused as a CRS classification.","A dual-resident entity has been reduced to one country without checking the amended standard and domestic implementation.","A reporting result is treated as an income-tax conclusion."],"sourceIds":["src-oecd-crs-2025","src-fatf-legal-persons-2023","src-fatf-legal-arrangements-2024","src-hmrc-vat-groups"]},{"cardinality":"many","classificationValues":[{"doesNotMean":"No agent, withholding or group role.","id":"obligation:taxpayer-and-filer","label":"Taxpayer and filer","meaning":"The same subject is charged and files for the stated obligation.","sourceIds":["src-hmrc-sole-trader-2026","src-charity-tax-exemptions"]},{"doesNotMean":"The filing unit is irrelevant.","id":"obligation:filing-unit-not-chargeable","label":"Filing unit, members charged","meaning":"The relationship computes or reports while members bear the underlying charge.","sourceIds":["src-hmrc-pm136000"]},{"doesNotMean":"Other members lose all liability.","id":"obligation:representative-member","label":"Representative member","meaning":"One member accounts for the group under the tax regime.","sourceIds":["src-hmrc-vat-groups"]},{"doesNotMean":"The employer is the employee's income-tax taxpayer.","id":"obligation:employer-withholder","label":"Employer or withholding role","meaning":"The subject deducts, reports or pays amounts connected with another person's income.","sourceIds":["src-hmrc-pm136000","src-hmrc-pm131450","src-govuk-paye-employers"]},{"doesNotMean":"Trustees are always the person strictly chargeable.","id":"obligation:trustee-administrator","label":"Trustee administration","meaning":"Trustees return, account or pay in an administrative capacity for the stated rule.","sourceIds":["src-hmrc-tsem1563","src-hmrc-tsem10020"]},{"doesNotMean":"The PE is a separately resident company.","id":"obligation:main-entity-pe-return","label":"Main entity with PE return","meaning":"The non-resident person reports and pays on profits attributed to its local presence.","sourceIds":["src-hmrc-branch-pe"]}],"id":"obligation-role","label":"Filing, payment and withholding role","meaning":"The person who files or remits can differ from the person on whom the underlying income or gain is charged.","origin":"Administrative and collection rules assign practical duties to taxpayers, partnerships, trustees, employers, agents and representative members.","question":"Who must calculate, return, pay, withhold or report?","reviewWhen":["A filing name is treated as proof of who bears the charge.","Partners, trustees, employers or VAT-group members share or divide duties.","A branch or agent submits on behalf of a non-resident.","Joint and several liability is possible."],"sourceIds":["src-hmrc-pm136000","src-hmrc-vat-groups","src-hmrc-tsem1563","src-hmrc-tsem10020","src-hmrc-branch-pe","src-hmrc-sole-trader-2026","src-hmrc-pm131450","src-charity-tax-exemptions","src-hmrc-intm180010","src-govuk-paye-employers"]}],"exampleProfiles":[{"archetypeIds":["archetype-sole-trader"],"asOf":"2026-07-28","assertions":[{"basis":"The person and sole trade are not separate legal persons.","classificationId":"legal:natural-person","dimensionId":"legal-existence","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Personal, employment and sole-trade capacities","jurisdiction":"United Kingdom","ruleset":"UK general law and HMRC sole-trader guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"General law"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"established"},{"basis":"The natural person is charged on their employment and trade income under the respective rules.","classificationId":"attribution:subject-level","dimensionId":"tax-attribution","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Employment income and independent design-trade profits","jurisdiction":"United Kingdom","ruleset":"UK Income Tax rules and HMRC sole-trader guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Income Tax"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"established"},{"basis":"Synthetic assumption limited to the employment engagement.","classificationId":"capacity:employee","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Synthetic employment engagement","jurisdiction":"United Kingdom","ruleset":"GOV.UK employment-status guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Employment status for tax"},"sourceIds":["src-govuk-employment-status"],"status":"established"},{"basis":"Synthetic assumption limited to the independent design trade.","classificationId":"capacity:sole-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Independent design trade","jurisdiction":"United Kingdom","ruleset":"HMRC sole-trader guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Income Tax"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"established"},{"basis":"Synthetic example assumption, not a residence assessment.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"2026-27 tax year synthetic assumption","jurisdiction":"United Kingdom","ruleset":"UK residence-based personal-tax framework as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Income Tax residence"},"sourceIds":["src-hmrc-rdrm20060"],"status":"established"},{"basis":"The example assumes the trade requires a Self Assessment return.","classificationId":"registration:self-assessment","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Independent design trade","jurisdiction":"United Kingdom","ruleset":"HMRC sole-trader administration guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Self Assessment"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"conditional"},{"basis":"The example contains no separate body or nominee.","classificationId":"control:legal-owner","dimensionId":"ownership-control","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Synthetic design-trade assets","jurisdiction":"United Kingdom","ruleset":"HMRC sole-trader guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"General law"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"established"},{"basis":"Reporting classification remains account and regime specific.","classificationId":"reporting:individual","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":"sole-trader-person","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"conditional"},{"basis":"The individual files their own assumed return; the employer separately withholds on employment pay.","classificationId":"obligation:taxpayer-and-filer","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Independent design-trade return","jurisdiction":"United Kingdom","ruleset":"HMRC sole-trader administration guidance as at 2026-07-28","subjectRef":"sole-trader-person","taxOrRegime":"Self Assessment"},"sourceIds":["src-hmrc-sole-trader-2026"],"status":"established"},{"basis":"The synthetic employer operates withholding for the employment engagement; it is not the taxpayer on the individual's trade profits.","classificationId":"obligation:employer-withholder","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-06","effectiveTo":null,"scope":{"activityOrContext":"Synthetic employment engagement","jurisdiction":"United Kingdom","ruleset":"GOV.UK employment-status guidance as at 2026-07-28","subjectRef":"synthetic-employer","taxOrRegime":"PAYE"},"sourceIds":["src-govuk-paye-employers"],"status":"established"}],"id":"example-employed-sole-trader","jurisdiction":"United Kingdom","label":"Employee with a separate sole trade","notDetermined":["Employment status from real contract facts.","Allowable expenses, VAT registration or MTD eligibility.","Any amount of tax."],"reviewTriggers":["Test employment status separately for each engagement.","Allocate mixed-use expenses to the capacity in which they were incurred.","Check VAT and MTD thresholds separately."],"subjects":[{"id":"sole-trader-person","kind":"natural-person","label":"Synthetic individual"},{"id":"synthetic-employer","kind":"employer","label":"Synthetic employer"}],"summary":"A synthetic UK-resident individual works under an employment contract and also carries on a design trade on their own account."},{"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."},{"archetypeIds":["archetype-charitable-company"],"asOf":"2026-07-28","assertions":[{"basis":"The company is incorporated.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-01-10","effectiveTo":null,"scope":{"activityOrContext":"Company limited by guarantee","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"charitable-company","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16"],"status":"established"},{"basis":"The charitable company remains the company taxpayer before applying relief provisions.","classificationId":"attribution:subject-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-01-10","effectiveTo":null,"scope":{"activityOrContext":"Synthetic trading income before relief conditions","jurisdiction":"United Kingdom","ruleset":"Finance Act 2010 charity framework and HMRC charity guidance as at 2026-07-28","subjectRef":"charitable-company","taxOrRegime":"Corporation Tax and charity exemptions"},"sourceIds":["src-charity-tax-exemptions"],"status":"established"},{"basis":"The synthetic example assumes charity-law and HMRC recognition.","classificationId":"capacity:charity","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-03-01","effectiveTo":null,"scope":{"activityOrContext":"Recognised charitable purposes","jurisdiction":"United Kingdom","ruleset":"Finance Act 2010 Part 1","subjectRef":"charitable-company","taxOrRegime":"Charity tax recognition"},"sourceIds":["src-finance-act-2010-charity"],"status":"established"},{"basis":"The company receives trading income.","classificationId":"capacity:company-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic trading activity","jurisdiction":"United Kingdom","ruleset":"HMRC charity tax-exemption guidance as at 2026-07-28","subjectRef":"charitable-company","taxOrRegime":"Corporation Tax and charity exemptions"},"sourceIds":["src-charity-tax-exemptions"],"status":"established"},{"basis":"UK incorporation supplies the normal domestic rule, subject to treaty exceptions.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-01-10","effectiveTo":null,"scope":{"activityOrContext":"UK-incorporated company","jurisdiction":"United Kingdom","ruleset":"UK incorporation residence rule and treaty exceptions as at 2026-07-28","subjectRef":"charitable-company","taxOrRegime":"Corporation Tax residence"},"sourceIds":["src-hmrc-intm120040"],"status":"conditional"},{"basis":"Both recognition layers are synthetic assumptions.","classificationId":"registration:charity-and-tax-recognition","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-03-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic recognised charity","jurisdiction":"United Kingdom","ruleset":"Finance Act 2010 Part 1 and applicable charity-law recognition","subjectRef":"charitable-company","taxOrRegime":"Charity-law and HMRC tax recognition"},"sourceIds":["src-finance-act-2010-charity"],"status":"established"},{"basis":"The company has members under its company form; the example makes no personal beneficial-ownership claim.","classificationId":"control:member","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-01-10","effectiveTo":null,"scope":{"activityOrContext":"Guarantee membership","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 and synthetic articles","subjectRef":"charitable-company-members","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16"],"status":"established"},{"basis":"Some qualifying non-profit entities can meet an Active NFE route, but the exact conditions and account facts must be checked.","classificationId":"reporting:active-nfe","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Qualifying non-profit Active NFE route for a hypothetical account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"charitable-company","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"conditional"},{"basis":"The company claims any available exemption in its company tax position.","classificationId":"obligation:taxpayer-and-filer","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Company tax position for synthetic trading income","jurisdiction":"United Kingdom","ruleset":"HMRC charity tax-exemption guidance as at 2026-07-28","subjectRef":"charitable-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-charity-tax-exemptions"],"status":"established"}],"id":"example-charitable-company-trade","jurisdiction":"United Kingdom","label":"Charitable company with trading income","notDetermined":["Whether the trading income is exempt.","Any Corporation Tax amount.","The real organisation's owners, controllers or CRS class."],"reviewTriggers":["Decide whether the trade is primary-purpose, beneficiary-run or within the small-trading exemption.","Trace application of income to charitable purposes.","Keep company, charity, employer and reporting roles separate."],"subjects":[{"id":"charitable-company","kind":"company-limited-by-guarantee","label":"Synthetic charitable company"},{"id":"charitable-company-members","kind":"member-class","label":"Synthetic guarantee members"}],"summary":"A synthetic UK company limited by guarantee is registered as a charity and receives trading income."},{"archetypeIds":["archetype-vat-group","archetype-private-company"],"asOf":"2026-07-28","assertions":[{"basis":"The VAT grouping does not create a fourth company.","classificationId":"legal:tax-group-not-person","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Approved VAT grouping","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"},{"basis":"The representative member remains a separate incorporated company.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Representative member's separate incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"vat-representative-company","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-vat-groups"],"status":"established"},{"basis":"VAT grouping does not end member B's separate company identity.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Member B's separate incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"vat-member-company-b","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-vat-groups"],"status":"established"},{"basis":"VAT grouping does not end member C's separate company identity.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Member C's separate incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"vat-member-company-c","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-vat-groups"],"status":"established"},{"basis":"The approved group is treated through one representative member for VAT.","classificationId":"attribution:single-vat-person","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Supplies made while all three companies are members","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"},{"basis":"The example assumes business activities within the VAT grouping rules.","classificationId":"capacity:independent-economic-actor","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Grouped economic activities","jurisdiction":"United Kingdom","ruleset":"UK VAT guidance as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT taxable-person rules"},"sourceIds":["src-hmrc-vat-guide-700"],"status":"conditional"},{"basis":"The VAT group has no separate residence from its members.","classificationId":"nexus:no-separate-residence","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Tax-specific group identity","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT grouping"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"},{"basis":"The example assumes approved membership and representative member.","classificationId":"registration:vat-group","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Approved group membership and representative member","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT registration"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"},{"basis":"The synthetic companies meet the relevant control condition.","classificationId":"control:common-control","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Control connection among the three member companies","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-group","taxOrRegime":"VAT group eligibility"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"},{"basis":"VAT grouping does not replace each company's classification under other regimes.","classificationId":"reporting:separate-members","dimensionId":"reporting-classification","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Effect of VAT grouping on member reporting classes","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"vat-representative-company","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"established"},{"basis":"The representative member submits the single VAT return and handles payment or repayment.","classificationId":"obligation:representative-member","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2026-04-01","effectiveTo":null,"scope":{"activityOrContext":"Single VAT return and payment account for the group","jurisdiction":"United Kingdom","ruleset":"VAT Notice 700/2 as at 2026-07-28","subjectRef":"vat-representative-company","taxOrRegime":"VAT"},"sourceIds":["src-hmrc-vat-groups"],"status":"established"}],"id":"example-three-company-vat-group","jurisdiction":"United Kingdom","label":"Three companies in one UK VAT group","notDetermined":["Eligibility or approval of any real VAT group.","VAT due or recoverable.","Corporation Tax, CRS or beneficial ownership of any member."],"reviewTriggers":["Confirm membership and representative member on each transaction date.","Check intra-group supply exceptions and overseas establishments.","Assess every member separately for non-VAT regimes."],"subjects":[{"id":"vat-group","kind":"vat-group","label":"Synthetic VAT group"},{"id":"vat-representative-company","kind":"company","label":"Synthetic representative company"},{"id":"vat-member-company-b","kind":"company","label":"Synthetic member company B"},{"id":"vat-member-company-c","kind":"company","label":"Synthetic member company C"}],"summary":"Three synthetic UK companies under common control have an approved VAT group with one representative member."},{"archetypeIds":["archetype-branch-pe"],"asOf":"2026-07-28","assertions":[{"basis":"The UK branch is part of the foreign company, not a subsidiary.","classificationId":"legal:non-separate-presence","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"UK office of the foreign company","jurisdiction":"United Kingdom","ruleset":"HMRC INTM162060 as at 2026-07-28","subjectRef":"uk-business-presence","taxOrRegime":"General law and Corporation Tax"},"sourceIds":["src-hmrc-branch-pe"],"status":"established"},{"basis":"The foreign company remains the taxpayer on profits attributed to the UK PE.","classificationId":"attribution:main-entity-with-presence","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"Profits attributed to the synthetic UK office","jurisdiction":"United Kingdom","ruleset":"Applicable UK law and treaty PE attribution rules as at 2026-07-28","subjectRef":"foreign-company","taxOrRegime":"Corporation Tax on PE-attributable profits"},"sourceIds":["src-hmrc-branch-pe","src-oecd-model-2017"],"status":"established"},{"basis":"The synthetic office carries on part of the company's trade.","classificationId":"capacity:company-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"Trade carried on partly through the UK office","jurisdiction":"United Kingdom","ruleset":"Applicable UK law and bilateral treaty as at 2026-07-28","subjectRef":"foreign-company","taxOrRegime":"Direct-tax business activity"},"sourceIds":["src-oecd-model-2017"],"status":"established"},{"basis":"The example assumes the applicable domestic and treaty tests are met.","classificationId":"nexus:permanent-establishment","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"Fixed UK office through which business is carried on","jurisdiction":"United Kingdom","ruleset":"Applicable UK domestic rule and actual treaty; OECD Model 2017 is comparison only","subjectRef":"uk-business-presence","taxOrRegime":"Corporation Tax and bilateral treaty"},"sourceIds":["src-oecd-model-2017"],"status":"conditional"},{"basis":"The direct-tax PE assumption does not settle the separate VAT fixed-establishment test.","classificationId":"nexus:vat-fixed-establishment","dimensionId":"residence-nexus","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Whether the UK office has suitable permanent human and technical resources","jurisdiction":"United Kingdom","ruleset":"HMRC VATPOSS04500 as at 2026-07-28","subjectRef":"uk-business-presence","taxOrRegime":"VAT place of supply"},"sourceIds":["src-hmrc-vat-fixed-establishment"],"status":"unknown"},{"basis":"Registration evidence alone does not establish the PE.","classificationId":"registration:none-determinative","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"Branch and tax registration evidence","jurisdiction":"United Kingdom","ruleset":"HMRC INTM162060 as at 2026-07-28","subjectRef":"uk-business-presence","taxOrRegime":"Corporation Tax permanent establishment"},"sourceIds":["src-hmrc-branch-pe"],"status":"established"},{"basis":"The example contains no shareholder or ultimate-control facts.","classificationId":"control:beneficial-owner","dimensionId":"ownership-control","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Natural-person ownership and control graph","jurisdiction":"Foreign formation jurisdiction and United Kingdom","ruleset":"FATF legal-person guidance subject to domestic implementation","subjectRef":"foreign-company","taxOrRegime":"Beneficial ownership"},"sourceIds":["src-fatf-legal-persons-2023"],"status":"unknown"},{"basis":"The example supplies no account, activity or reporting facts; 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 and foreign residence jurisdictions","ruleset":"OECD CRS 2025 subject to domestic implementation","subjectRef":"foreign-company","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The example supplies no account, activity or reporting facts; 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 and foreign residence jurisdictions","ruleset":"OECD CRS 2025 subject to domestic implementation","subjectRef":"foreign-company","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The example supplies no account, activity or reporting facts; 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 and foreign residence jurisdictions","ruleset":"OECD CRS 2025 subject to domestic implementation","subjectRef":"foreign-company","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The non-resident company reports the profits attributed to its UK presence.","classificationId":"obligation:main-entity-pe-return","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-10-01","effectiveTo":null,"scope":{"activityOrContext":"Return of profits attributed to the UK PE","jurisdiction":"United Kingdom","ruleset":"HMRC INTM162060 as at 2026-07-28","subjectRef":"foreign-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-branch-pe"],"status":"established"}],"id":"example-foreign-company-uk-pe","jurisdiction":"United Kingdom and foreign formation jurisdiction","label":"Foreign company with a UK permanent establishment","notDetermined":["Whether a real PE exists.","Profits attributable to a PE.","VAT, payroll, residence, ownership or reporting outcomes."],"reviewTriggers":["Read the actual treaty and domestic rule.","Separate PE existence from profit attribution.","Assess VAT fixed establishment, payroll and branch registration independently."],"subjects":[{"id":"foreign-company","kind":"company","label":"Synthetic foreign company"},{"id":"uk-business-presence","kind":"non-separate-presence","label":"Synthetic UK office and business presence"}],"summary":"A synthetic non-UK company carries on part of its business through a UK office that the example assumes meets the applicable PE test."},{"archetypeIds":["archetype-express-trust"],"asOf":"2026-07-28","assertions":[{"basis":"The trust is a relationship governing property and roles.","classificationId":"legal:legal-arrangement","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Property held on synthetic bare-trust terms","jurisdiction":"England and Wales","ruleset":"English trust law and FATF legal-arrangement model as at 2026-07-28","subjectRef":"bare-trust-arrangement","taxOrRegime":"Trust law"},"sourceIds":["src-fatf-legal-arrangements-2024"],"status":"established"},{"basis":"The example assumes immediate and absolute entitlement satisfying the bare-trust treatment.","classificationId":"attribution:beneficiary-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Income and gains from the bare-trust property","jurisdiction":"United Kingdom","ruleset":"HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-beneficiary","taxOrRegime":"Income Tax and Capital Gains Tax"},"sourceIds":["src-hmrc-tsem1563"],"status":"conditional"},{"basis":"The trustees hold and administer the legal title.","classificationId":"capacity:trustee","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Holding and administering legal title","jurisdiction":"England and Wales","ruleset":"Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-trustees","taxOrRegime":"Trust law"},"sourceIds":["src-hmrc-tsem1563"],"status":"established"},{"basis":"The synthetic adult has immediate and absolute beneficial entitlement.","classificationId":"capacity:beneficiary","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Immediate and absolute entitlement to capital and income","jurisdiction":"England and Wales","ruleset":"Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-beneficiary","taxOrRegime":"Trust law"},"sourceIds":["src-hmrc-tsem1563"],"status":"established"},{"basis":"No trustee, settlor or beneficiary residence facts are supplied.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Deemed trustee body for the synthetic settlement","jurisdiction":"United Kingdom","ruleset":"HMRC TSEM10020 as at 2026-07-28","subjectRef":"bare-trust-trustees","taxOrRegime":"Trustee residence for Income Tax and Capital Gains Tax"},"sourceIds":["src-hmrc-tsem10020"],"status":"unknown"},{"basis":"Registration does not decide beneficial entitlement or the person charged.","classificationId":"registration:none-determinative","dimensionId":"registration-grouping","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Effect of registration on beneficial entitlement and attribution","jurisdiction":"United Kingdom","ruleset":"HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-arrangement","taxOrRegime":"Trust administration"},"sourceIds":["src-hmrc-tsem1563"],"status":"established"},{"basis":"Trustees hold legal title under the synthetic arrangement.","classificationId":"control:trustee-legal-title","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Legal title to the trust property","jurisdiction":"England and Wales","ruleset":"Synthetic trust terms and FATF legal-arrangement guidance","subjectRef":"bare-trust-trustees","taxOrRegime":"Trust ownership"},"sourceIds":["src-fatf-legal-arrangements-2024"],"status":"established"},{"basis":"The beneficiary has immediate and absolute beneficial entitlement.","classificationId":"control:beneficiary-interest","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Immediate and absolute beneficial interest","jurisdiction":"England and Wales","ruleset":"Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-beneficiary","taxOrRegime":"Trust ownership"},"sourceIds":["src-hmrc-tsem1563"],"status":"established"},{"basis":"CRS analysis names trust roles separately; actual reporting depends on the account and domestic implementation.","classificationId":"reporting:trust-roles","dimensionId":"reporting-classification","effectiveDateBasis":"current-at-corpus-review","effectiveFrom":null,"effectiveTo":null,"scope":{"activityOrContext":"Trust-role analysis for a hypothetical financial account","jurisdiction":"United Kingdom","ruleset":"OECD CRS 2025 subject to UK implementation","subjectRef":"bare-trust-arrangement","taxOrRegime":"Common Reporting Standard"},"sourceIds":["src-oecd-crs-2025"],"status":"conditional"},{"basis":"Trustees may act administratively even where the beneficiary is strictly chargeable.","classificationId":"obligation:trustee-administrator","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2022-06-01","effectiveTo":null,"scope":{"activityOrContext":"Administrative action for income and gains strictly chargeable on the beneficiary","jurisdiction":"United Kingdom","ruleset":"HMRC TSEM1563 as at 2026-07-28","subjectRef":"bare-trust-trustees","taxOrRegime":"Income Tax and Capital Gains Tax administration"},"sourceIds":["src-hmrc-tsem1563"],"status":"conditional"}],"id":"example-bare-trust","jurisdiction":"United Kingdom","label":"Bare trust with an absolutely entitled adult beneficiary","notDetermined":["The legal effect of a real trust instrument.","Residence or reporting obligations.","Any tax liability, return requirement or beneficial-owner record."],"reviewTriggers":["Obtain legal review if bare-trust status is uncertain.","Assess each income and gain under its charging rule.","Resolve trustee, settlor and beneficiary residence and reporting positions separately."],"subjects":[{"id":"bare-trust-arrangement","kind":"legal-arrangement","label":"Synthetic bare-trust arrangement"},{"id":"bare-trust-trustees","kind":"trustee-body","label":"Synthetic trustees acting together"},{"id":"bare-trust-beneficiary","kind":"natural-person-beneficiary","label":"Synthetic absolutely entitled adult beneficiary"}],"summary":"A synthetic English-law bare trust has trustees holding legal title and one adult beneficiary with immediate and absolute title to capital and income."},{"archetypeIds":["archetype-private-company"],"asOf":"2026-07-28","assertions":[{"basis":"The UK company remains a body corporate separate from its sole owner.","classificationId":"legal:body-corporate","dimensionId":"legal-existence","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic company incorporation","jurisdiction":"United Kingdom","ruleset":"Companies Act 2006 section 16","subjectRef":"hybrid-uk-company","taxOrRegime":"Company law"},"sourceIds":["src-companies-act-2006-s16","src-hmrc-hybrid-entities"],"status":"established"},{"basis":"The incorporated company is the UK Corporation Tax subject for the synthetic trade.","classificationId":"attribution:subject-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United Kingdom","ruleset":"UK company-tax treatment as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities","src-hmrc-intm180010"],"status":"established"},{"basis":"The example assumes a valid owner-level US federal classification; it does not ask the UK to follow that classification.","classificationId":"attribution:owner-level","dimensionId":"tax-attribution","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade profits","jurisdiction":"United States","ruleset":"US entity-classification rules and the synthetic valid classification as at 2026-07-28","subjectRef":"hybrid-sole-owner","taxOrRegime":"US federal income tax"},"sourceIds":["src-irs-entity-classification-2026","src-hmrc-hybrid-entities"],"status":"conditional"},{"basis":"The company, rather than its owner acting personally, carries on the synthetic trade under UK law.","classificationId":"capacity:company-trader","dimensionId":"capacity-activity","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"},{"basis":"UK incorporation supplies the normal domestic residence rule, subject to statutory and treaty exceptions.","classificationId":"nexus:uk-domestic-resident","dimensionId":"residence-nexus","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"UK-incorporated synthetic company","jurisdiction":"United Kingdom","ruleset":"UK incorporation residence rule and treaty exceptions as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax residence"},"sourceIds":["src-hmrc-intm120040"],"status":"conditional"},{"basis":"The example assumes an available and valid US election from the stated date; the election does not change the UK legal form.","classificationId":"registration:classification-election","dimensionId":"registration-grouping","effectiveDateBasis":"stated-interval","effectiveFrom":"2025-01-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic valid classification election","jurisdiction":"United States","ruleset":"US check-the-box rules as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"US federal entity classification"},"sourceIds":["src-irs-entity-classification-2026","src-us-check-box-1996"],"status":"conditional"},{"basis":"The synthetic facts state one natural-person ultimate owner; this role is separate from both countries' tax-attribution results.","classificationId":"control:beneficial-owner","dimensionId":"ownership-control","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic sole ownership and ultimate control","jurisdiction":"United Kingdom","ruleset":"FATF legal-person guidance subject to UK implementation","subjectRef":"hybrid-sole-owner","taxOrRegime":"Beneficial ownership"},"sourceIds":["src-fatf-legal-persons-2023"],"status":"established"},{"basis":"No account, income, asset or reporting-implementation facts are 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 and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are 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 and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"No account, income, asset or reporting-implementation facts are 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 and United States","ruleset":"Applicable reporting regime and domestic implementation","subjectRef":"hybrid-uk-company","taxOrRegime":"CRS and FATCA"},"sourceIds":["src-oecd-crs-2025"],"status":"unknown"},{"basis":"The company remains the UK taxpayer and filer even though the US federal attribution in this example points to its owner.","classificationId":"obligation:taxpayer-and-filer","dimensionId":"obligation-role","effectiveDateBasis":"stated-interval","effectiveFrom":"2024-02-01","effectiveTo":null,"scope":{"activityOrContext":"Synthetic software trade return","jurisdiction":"United Kingdom","ruleset":"UK Corporation Tax framework as at 2026-07-28","subjectRef":"hybrid-uk-company","taxOrRegime":"Corporation Tax"},"sourceIds":["src-hmrc-hybrid-entities"],"status":"established"}],"id":"example-uk-company-us-disregarded","jurisdiction":"United Kingdom and United States","label":"UK company with a different US federal tax classification","notDetermined":["Whether any real company is eligible for or made a US classification election.","Any hybrid-mismatch, treaty, reporting or filing consequence.","Any amount of tax."],"reviewTriggers":["Verify that the foreign classification or election is legally available and effective.","Read the exact UK charge, US federal rule and any hybrid-mismatch or treaty provision.","Do not infer reporting, residence or beneficial ownership from either tax classification."],"subjects":[{"id":"hybrid-uk-company","kind":"private-limited-company","label":"Synthetic UK company"},{"id":"hybrid-sole-owner","kind":"natural-person-owner","label":"Synthetic sole natural-person owner"}],"summary":"A synthetic UK-incorporated company carries on a software trade. The example assumes a valid US federal classification under which its sole owner is charged on the same trade profits while the company remains the UK Corporation Tax subject."}],"gaps":[{"id":"gap-no-cross-jurisdiction-form-equivalence","safeNextStep":"Read the foreign governing law, constitutional documents and the applying jurisdiction's classification rule.","status":"intentionally-not-generalised","title":"No universal legal-form equivalence","why":"The same translated label can carry different rights and tax treatment. This release does not claim that UK company, partnership or trust forms map one-to-one to foreign forms."},{"id":"gap-no-complete-tax-table","safeNextStep":"Assess the exact charge, item, capacity, jurisdiction and period.","status":"coverage-gap","title":"No all-tax outcome table","why":"A form-by-tax table would falsely imply that the form alone determines each outcome."},{"id":"gap-no-treaty-substitute","safeNextStep":"Read the current treaty text and domestic implementation for both states.","status":"coverage-gap","title":"No bilateral-treaty result","why":"The OECD Model explains concepts but actual treaties and protocols differ."},{"id":"gap-no-private-control-graph","safeNextStep":"Keep verified private records in an approved matter or compliance system with access controls.","status":"privacy-boundary","title":"No natural-person ownership or control graph","why":"Beneficial ownership can be sensitive personal data and this public corpus contains only roles and synthetic examples."},{"id":"gap-no-personal-assessment-api","safeNextStep":"Use the schema locally, retain sources and facts, and obtain qualified review for consequential cases.","status":"effect-boundary","title":"No hosted personal classification","why":"This release is a public framework and synthetic interpreter. It accepts no private facts and makes no authority-facing decision."},{"id":"gap-no-confidence-score","safeNextStep":"Report missing facts, competing classifications, source authority and a plain review reason.","status":"method-boundary","title":"No numerical legal confidence","why":"A percentage would hide whether the gap is law, evidence, dates, jurisdiction or contested authority."},{"id":"gap-community-interest-companies","safeNextStep":"Add CIC legislation, regulator status, company-tax treatment, control and activity-specific examples before classifying one.","status":"coverage-gap","title":"Community interest companies not yet modelled","why":"A CIC combines company form with a separate community-interest and asset-lock regime; the current company and charity archetypes do not express that combination."},{"id":"gap-charitable-incorporated-organisations","safeNextStep":"Add separate England and Wales, Scotland and Northern Ireland form and tax sources rather than mapping a CIO to a company by name.","status":"coverage-gap","title":"Charitable incorporated organisations not yet modelled","why":"A CIO is an incorporated charity form without the same Companies Act identity as a charitable company."},{"id":"gap-limited-partnerships","safeNextStep":"Model each territorial form, partner role, charge and effective period from the Limited Partnerships Act and current tax guidance.","status":"coverage-gap","title":"Limited partnerships not yet modelled","why":"General partners, limited partners, Scottish legal personality, private-fund rules and registration changes require more than the general-partnership archetypes."},{"id":"gap-mutuals","safeNextStep":"Split the family by statute and activity before adding legal-form, attribution, reporting and obligation classifications.","status":"coverage-gap","title":"Mutuals not yet modelled","why":"Co-operative societies, community benefit societies, friendly societies, building societies and other mutual forms have different governing and tax rules."},{"id":"gap-unincorporated-associations","safeNextStep":"Add governing-law, Corporation Tax, trust-property and officer-duty sources with separate synthetic subjects.","status":"coverage-gap","title":"Unincorporated associations not yet modelled","why":"An association can lack separate general-law personality while tax and administration still assign duties to officers, trustees or the association name."},{"id":"gap-statutory-bodies","safeNextStep":"Model each statutory body's creating instrument, tax provision, public function and filing role separately.","status":"coverage-gap","title":"Statutory bodies not yet modelled","why":"Public corporations, authorities and office-holders derive identity and exemptions from their own enactments rather than one reusable company rule."},{"id":"gap-investment-vehicles","safeNextStep":"Add vehicle-specific legal, regulatory, tax-attribution, reporting and election sources before publishing classifications.","status":"coverage-gap","title":"Investment vehicles not yet modelled","why":"REITs, investment trusts, OEICs, unit trusts, limited-partnership funds and other vehicles combine legal form, elections, regulatory status and investor-level tax in different ways."}],"meta":{"boundaries":["No names, tax identifiers, addresses, ownership records or private taxpayer facts.","No endpoint accepts a person's or organisation's facts in this release.","No eligibility, liability, residence, employment-status, beneficial-owner or permanent-establishment decision.","No filing, payment, registration, authority contact or external state change.","No numerical confidence score; gaps and review triggers are stated in words."],"contentLicence":{"name":"CC BY-SA 4.0","scope":"CC BY-SA 4.0 covers only TaxSorted-authored curation, summaries, schema structure and synthetic examples in this corpus. It does not relicense legislation, official guidance, model standards, linked source text, trademarks or other third-party material; each source keeps its own rights and reuse terms.","url":"https://creativecommons.org/licenses/by-sa/4.0/"},"editorialRules":["Never collapse legal form, taxable person, reporting person and beneficial owner into one label.","Every assertion states subjectRef, jurisdiction, taxOrRegime, activityOrContext, ruleset, status and an effective-date basis.","Treat identifiers and registrations as evidence, not as proof of the underlying classification.","Keep unknown, conditional, disputed and not-applicable distinct.","Model a branch, permanent establishment or VAT fixed establishment as a nexus overlay unless local law creates a separate legal person.","A model convention or international standard is not enacted domestic law or the text of an actual treaty.","A change creates a new effective-dated assertion; it does not rewrite the earlier one.","Every classification is individually sourced, its source IDs are included in the parent dimension source list, and every synthetic subject is used by at least one assertion."],"jurisdiction":"United Kingdom","lawAsAt":"2026-07-28","portability":"The dimensions are jurisdiction-portable. The classifications, examples and legal conclusions in this release are UK-first and must not be copied to another jurisdiction without local sources.","purpose":"Explain how legal existence, tax treatment, residence, activity, control, reporting and filing identity can point to different subjects at the same time.","reviewedOn":"2026-07-28","title":"UK tax identity framework","version":"2026-07-28.2","warning":"Educational public reference only. It is not legal advice, an authority determination, a filing position or a substitute for the exact law and facts for the tax, place and period in question."},"milestones":[{"archetypeIds":["archetype-english-general-partnership","archetype-scottish-partnership"],"change":"The Partnership Act 1890 put the statutory relationship definition and the Scottish legal-person rule into one Act.","continuity":"Partnership was not invented in 1890, and later tax statutes still decide charge-specific treatment.","date":"1890-08-14","dimensionIds":["legal-existence"],"eventType":"codified","id":"milestone-1890-partnership-codification","sourceIds":["src-partnership-act-1890-s1","src-partnership-act-1890-s4"],"title":"Partnership law declared and amended"},{"archetypeIds":["archetype-private-company","archetype-charitable-company"],"change":"The statutory incorporation rule joined the older central-management-and-control doctrine.","continuity":"Management facts and treaty coordination remain relevant; registered office and residence are not synonyms.","date":"1988-03-15","dimensionIds":["residence-nexus"],"eventType":"introduced-rule","id":"milestone-1988-incorporation-residence","sourceIds":["src-hmrc-intm120040","src-hmrc-intm120180"],"title":"UK company residence gained an incorporation rule"},{"archetypeIds":["archetype-vat-group"],"change":"The current statutory framework permits eligible persons to be treated together for VAT through a representative member.","continuity":"Members keep separate legal identities and can retain liability.","date":"1994-07-05","dimensionIds":["tax-attribution","registration-grouping","obligation-role"],"eventType":"consolidated","id":"milestone-1994-vat-consolidation","sourceIds":["src-hmrc-vat-groups"],"title":"VAT Act 1994 consolidated VAT grouping rules"},{"archetypeIds":["archetype-private-company","archetype-gb-llp"],"change":"Eligible entities gained default and elective US federal tax classifications that can diverge from legal form.","continuity":"The election does not change the state-law entity or compel another country to follow it.","date":"1997-01-01","dimensionIds":["tax-attribution","registration-grouping"],"eventType":"introduced-election","id":"milestone-1997-us-check-box","sourceIds":["src-us-check-box-1996","src-irs-entity-classification-2026"],"title":"US check-the-box classification became applicable"},{"archetypeIds":["archetype-gb-llp"],"change":"The LLP Act 2000 created a body corporate with personality separate from its members for England, Wales and Scotland.","continuity":"Northern Ireland initially followed a separate 2002 Act; tax legislation separately supplies normal partnership treatment when its conditions are met.","date":"2000-07-20","dimensionIds":["legal-existence","tax-attribution"],"eventType":"created-form","id":"milestone-2000-gb-llp-created","sourceIds":["src-llp-act-2000-s1","src-hmrc-pm131450"],"title":"Parliament created the Great Britain LLP form"},{"archetypeIds":["archetype-ni-llp"],"change":"The Northern Ireland Act created an LLP body corporate with personality separate from its members.","continuity":"This separate Act was later ended when the Great Britain LLP enactments were extended to Northern Ireland.","date":"2002-11-22","dimensionIds":["legal-existence"],"eventType":"created-form","id":"milestone-2002-ni-llp-created","sourceIds":["src-ni-llp-act-2002-s1"],"title":"Northern Ireland created a separate LLP form"},{"archetypeIds":["archetype-private-company","archetype-charitable-company"],"change":"The current company-law framework states that registration forms the body corporate.","continuity":"Tax, charity, reporting and control overlays remain separate questions.","date":"2006-11-08","dimensionIds":["legal-existence","registration-grouping"],"eventType":"consolidated","id":"milestone-2006-companies-consolidation","sourceIds":["src-companies-act-2006-s16"],"title":"Companies Act 2006 restated the incorporation effect"},{"archetypeIds":["archetype-gb-llp","archetype-ni-llp"],"change":"Companies Act 2006 section 1286 provided for the Great Britain LLP enactments to extend to Northern Ireland and for the separate 2002 Act to cease to have effect.","continuity":"Point-in-time work still needs formation, commencement and transitional facts.","date":"2006-11-08","dimensionIds":["legal-existence","registration-grouping"],"eventType":"consolidated","id":"milestone-2006-llp-extension-ni","sourceIds":["src-companies-act-2006-s1286","src-ni-llp-act-2002-s1"],"title":"Parliament provided for Great Britain LLP legislation to extend to Northern Ireland"},{"archetypeIds":["archetype-charitable-company","archetype-express-trust"],"change":"Tax legislation supplied cross-tax definitions of charity, charitable company and charitable trust.","continuity":"The legal form and the conditions of each relief still matter.","date":"2010-04-08","dimensionIds":["capacity-activity","registration-grouping","tax-attribution"],"eventType":"consolidated","id":"milestone-2010-tax-charity-definition","sourceIds":["src-finance-act-2010-charity","src-charity-tax-exemptions"],"title":"Finance Act 2010 aligned core tax charity definitions"},{"archetypeIds":["archetype-branch-pe"],"change":"The OECD final report proposed changes addressing commissionnaire arrangements, preparatory or auxiliary exceptions, fragmentation and contract splitting.","continuity":"A model-standard change does not itself create a UK PE; the actual treaty, domestic law, effective date and facts remain controlling.","date":"2015-10-05","dimensionIds":["residence-nexus","tax-attribution"],"eventType":"strengthened-standard","id":"milestone-2015-pe-action-7","sourceIds":["src-oecd-beps-action-7-2015","src-oecd-model-2017"],"title":"BEPS Action 7 strengthened the model PE tests"},{"archetypeIds":["archetype-private-company","archetype-charitable-company"],"change":"Revised Recommendation 24 strengthened access to adequate, accurate and up-to-date natural-person ownership and control information.","continuity":"Beneficial ownership remains distinct from legal title, tax liability and guilt.","date":"2022-03-04","dimensionIds":["ownership-control"],"eventType":"strengthened-standard","id":"milestone-2022-fatf-control","sourceIds":["src-fatf-legal-persons-2023"],"title":"FATF strengthened legal-person beneficial-ownership standards"},{"archetypeIds":["archetype-sole-trader","archetype-express-trust"],"change":"HMRC states that from 6 April 2025 domicile ceased to be the relevant connecting factor in the changed regime and residence-based rules apply.","continuity":"Domicile remains relevant to historical periods and must not be silently erased.","date":"2025-04-06","dimensionIds":["residence-nexus"],"eventType":"changed-connecting-factor","id":"milestone-2025-uk-residence-shift","sourceIds":["src-hmrc-rdrm20060"],"title":"Residence replaced domicile in the reformed personal-tax scope"},{"archetypeIds":["archetype-private-company","archetype-express-trust"],"change":"The consolidation brings the original and amended reporting classifications and controlling-person rules together.","continuity":"Domestic adoption and later exchange dates govern actual obligations.","date":"2025-04","dimensionIds":["reporting-classification","ownership-control"],"eventType":"consolidated-standard","id":"milestone-2025-crs-consolidation","sourceIds":["src-oecd-crs-2025"],"title":"OECD consolidated the amended CRS"}],"overlaps":[{"archetypeIds":["archetype-sole-trader"],"dangerousShortcut":"Creating a fictional second person called the business, or treating every personal item as a business item.","dimensionIds":["legal-existence","capacity-activity","obligation-role"],"id":"overlap-person-and-business-capacity","label":"One person, personal and business capacities","meaning":"There is one legal person, but transactions and expenses still have to be assigned to the correct personal, employment, trading or other capacity.","questions":["Which activity produced the item?","Was the person acting independently or under an employment relationship?","Which registration covers the activity?"],"relations":[{"field":"subjectRef","leftRequirementId":"legal-person","operator":"same","rightRequirementId":"business-capacity"},{"field":"jurisdiction","leftRequirementId":"legal-person","operator":"same","rightRequirementId":"business-capacity"}],"requires":[{"classificationId":"legal:natural-person","dimensionId":"legal-existence","id":"legal-person"},{"classificationId":"capacity:sole-trader","dimensionId":"capacity-activity","id":"business-capacity"}],"reviewTriggers":["Mixed employment and self-employment.","Shared personal and business assets or expenses.","More than one trade or partnership role."],"sourceIds":["src-hmrc-sole-trader-2026","src-govuk-employment-status"]},{"archetypeIds":["archetype-gb-llp","archetype-ni-llp"],"dangerousShortcut":"Calling the LLP a company taxpayer because it is incorporated, or calling it legally unincorporated because it is transparent.","dimensionIds":["legal-existence","tax-attribution","obligation-role"],"id":"overlap-body-corporate-and-member-taxation","label":"Separate body corporate, member-level taxation","meaning":"The LLP owns, contracts and files as a body corporate while the relevant income and gains are normally attributed to members.","questions":["Is it carrying on a business with a view to profit?","Which tax and item are being classified?","Do the salaried-member or winding-up exceptions matter?"],"relations":[{"field":"subjectRef","leftRequirementId":"llp-body","operator":"different","rightRequirementId":"members-charged"}],"requires":[{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","id":"llp-body"},{"classificationId":"attribution:member-level","dimensionId":"tax-attribution","id":"members-charged"}],"reviewTriggers":["Non-profit activity, winding up or temporary cessation.","A member may fall within salaried-members rules.","Another jurisdiction classifies the LLP."],"sourceIds":["src-llp-act-2000-s1","src-hmrc-pm131450","src-hmrc-hybrid-entities"]},{"archetypeIds":["archetype-scottish-partnership"],"dangerousShortcut":"Applying either the English legal answer or an entity-level tax answer merely because the firm is a person.","dimensionIds":["legal-existence","tax-attribution"],"id":"overlap-separate-scottish-firm-and-member-taxation","label":"Separate Scottish firm, member-level taxation","meaning":"Scots law can recognise the firm as a person while UK partnership tax still looks through to partners.","questions":["Which UK law territory governs the firm?","Which charge and filing duty are in view?"],"relations":[{"field":"subjectRef","leftRequirementId":"scottish-firm","operator":"different","rightRequirementId":"partners-charged"},{"field":"jurisdiction","leftRequirementId":"scottish-firm","operator":"same","rightRequirementId":"partners-charged"}],"requires":[{"classificationId":"legal:separate-firm-person","dimensionId":"legal-existence","id":"scottish-firm"},{"classificationId":"attribution:member-level","dimensionId":"tax-attribution","id":"partners-charged"}],"reviewTriggers":["The place of formation or governing law is unclear.","The structure includes limited partnerships or cross-border partners."],"sourceIds":["src-partnership-act-1890-s4","src-hmrc-pm136000"]},{"archetypeIds":["archetype-charitable-company"],"dangerousShortcut":"Replacing the legal form with charity, or replacing a conditional exemption with tax-free.","dimensionIds":["legal-existence","capacity-activity","registration-grouping","tax-attribution"],"id":"overlap-company-and-charity","label":"Company form and charity status","meaning":"The company remains a company taxpayer while charity status can provide conditional reliefs for qualifying income and use.","questions":["Which legal form does the charity use?","Is the income from a qualifying activity?","Is the income or gain applied to charitable purposes?"],"relations":[{"field":"subjectRef","leftRequirementId":"company-body","operator":"same","rightRequirementId":"charity-capacity"},{"field":"subjectRef","leftRequirementId":"company-body","operator":"same","rightRequirementId":"company-charge"}],"requires":[{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","id":"company-body"},{"classificationId":"capacity:charity","dimensionId":"capacity-activity","id":"charity-capacity"},{"classificationId":"attribution:subject-level","dimensionId":"tax-attribution","id":"company-charge"}],"reviewTriggers":["Non-primary-purpose trading.","Mixed charitable and non-charitable expenditure.","Registration and HMRC recognition do not align."],"sourceIds":["src-finance-act-2010-charity","src-charity-tax-exemptions","src-companies-act-2006-s16"]},{"archetypeIds":["archetype-vat-group"],"dangerousShortcut":"Propagating the VAT-group identity to Corporation Tax, CRS, ownership or contracts.","dimensionIds":["legal-existence","tax-attribution","registration-grouping","obligation-role"],"id":"overlap-separate-companies-one-vat-person","label":"Separate companies, one VAT taxable person","meaning":"VAT treats eligible members as one taxable person through a representative member; their company-law and other-tax identities remain separate.","questions":["Which bodies were members on the transaction date?","Who was the representative member?","Does a statutory exception stop an intra-group supply being disregarded?"],"relations":[{"field":"subjectRef","leftRequirementId":"member-company","operator":"different","rightRequirementId":"vat-group-shell"},{"field":"subjectRef","leftRequirementId":"vat-group-shell","operator":"same","rightRequirementId":"vat-taxable-person"}],"requires":[{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","id":"member-company"},{"classificationId":"legal:tax-group-not-person","dimensionId":"legal-existence","id":"vat-group-shell"},{"classificationId":"attribution:single-vat-person","dimensionId":"tax-attribution","id":"vat-taxable-person"}],"reviewTriggers":["Membership or representative member changed.","Overseas establishments or bought-in services are involved.","Joint and several liability matters."],"sourceIds":["src-hmrc-vat-groups"]},{"archetypeIds":["archetype-branch-pe"],"dangerousShortcut":"Treating the PE as a resident subsidiary or treating non-separate as non-taxable.","dimensionIds":["legal-existence","residence-nexus","tax-attribution"],"id":"overlap-non-separate-presence-with-tax-nexus","label":"No new legal person, but a local tax presence","meaning":"The branch or PE is part of the foreign person, yet its local activity can create and measure a local charge.","questions":["Which domestic law and treaty definition applies?","What activity, place or agent creates the nexus?","What profit is attributable after the existence question is answered?"],"relations":[{"field":"subjectRef","leftRequirementId":"uk-presence","operator":"different","rightRequirementId":"foreign-company-charge"},{"field":"subjectRef","leftRequirementId":"uk-presence","operator":"same","rightRequirementId":"uk-pe-nexus"}],"requires":[{"classificationId":"legal:non-separate-presence","dimensionId":"legal-existence","id":"uk-presence"},{"classificationId":"attribution:main-entity-with-presence","dimensionId":"tax-attribution","id":"foreign-company-charge"},{"classificationId":"nexus:permanent-establishment","dimensionId":"residence-nexus","id":"uk-pe-nexus"}],"reviewTriggers":["Remote staff or dependent agents.","A subsidiary also performs parent activity.","Direct-tax PE and VAT fixed-establishment results differ."],"sourceIds":["src-hmrc-branch-pe","src-oecd-model-2017","src-hmrc-vat-fixed-establishment"]},{"archetypeIds":["archetype-express-trust"],"dangerousShortcut":"Naming one universal owner or taxpayer for the trust.","dimensionIds":["legal-existence","tax-attribution","ownership-control","reporting-classification","obligation-role"],"id":"overlap-trust-title-benefit-and-attribution","label":"Trust legal title, benefit, control and tax attribution","meaning":"Trustees can hold legal title, beneficiaries can hold or expect benefit, reporting regimes can name controlling roles, and tax can attribute an item to trustees, beneficiaries or a settlor.","questions":["What type of trust and entitlement exists?","Which income, gain, tax and period are in view?","Which role is being asked about: title, benefit, control, charge or filing?"],"relations":[{"field":"subjectRef","leftRequirementId":"trust-arrangement","operator":"different","rightRequirementId":"trustees-title"},{"field":"subjectRef","leftRequirementId":"trust-arrangement","operator":"different","rightRequirementId":"beneficiary-interest"},{"field":"subjectRef","leftRequirementId":"trustees-title","operator":"different","rightRequirementId":"beneficiary-interest"}],"requires":[{"classificationId":"legal:legal-arrangement","dimensionId":"legal-existence","id":"trust-arrangement"},{"classificationId":"control:trustee-legal-title","dimensionId":"ownership-control","id":"trustees-title"},{"classificationId":"control:beneficiary-interest","dimensionId":"ownership-control","id":"beneficiary-interest"}],"reviewTriggers":["Bare-trust status is uncertain.","Settlor-interest rules may apply.","Classes of beneficiaries, protectors or cross-border residence are present."],"sourceIds":["src-hmrc-tsem1563","src-hmrc-tsem4200","src-fatf-legal-arrangements-2024","src-oecd-crs-2025"]},{"archetypeIds":["archetype-gb-llp","archetype-private-company"],"dangerousShortcut":"Forcing one country-wide entity type or treating the mismatch as dirty data.","dimensionIds":["legal-existence","tax-attribution","residence-nexus","registration-grouping"],"id":"overlap-cross-border-hybrid","label":"One legal form, different countries' tax classifications","meaning":"A jurisdiction can treat a body as separate while another looks through it or follows an election. Both classifications can be correct in their own scopes.","questions":["Which jurisdiction, charge and period does each classification cover?","Was an election made and when did it take effect?","Do anti-hybrid, treaty or reporting rules respond to the mismatch?"],"relations":[{"field":"subjectRef","leftRequirementId":"legal-entity","operator":"same","rightRequirementId":"subject-level-charge"},{"field":"subjectRef","leftRequirementId":"subject-level-charge","operator":"different","rightRequirementId":"owner-level-charge"},{"field":"jurisdiction","leftRequirementId":"subject-level-charge","operator":"different","rightRequirementId":"owner-level-charge"},{"field":"activityOrContext","leftRequirementId":"subject-level-charge","operator":"same","rightRequirementId":"owner-level-charge"}],"requires":[{"classificationId":"legal:body-corporate","dimensionId":"legal-existence","id":"legal-entity"},{"classificationId":"attribution:subject-level","dimensionId":"tax-attribution","id":"subject-level-charge"},{"classificationId":"attribution:owner-level","dimensionId":"tax-attribution","id":"owner-level-charge"}],"reviewTriggers":["A foreign entity, election or disregarded status appears.","Payments cross between differently classified entities.","Treaty entitlement or hybrid-mismatch rules may matter."],"sourceIds":["src-hmrc-intm180010","src-irs-entity-classification-2026","src-us-check-box-1996","src-hmrc-hybrid-entities"]}],"schema":"taxsorted.uk.tax-identity/1","sources":[{"authorityLevel":"legislation","id":"src-partnership-act-1890-s1","jurisdiction":"United Kingdom","limitations":["Legal personality differs within the UK and tax statutes can apply a different treatment."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["The statutory partnership definition is a relationship between persons carrying on business in common with a view of profit.","The 1890 Act declared and amended an existing field of partnership law rather than inventing every partnership relationship."],"title":"Partnership Act 1890, section 1","url":"https://www.legislation.gov.uk/ukpga/Vict/53-54/39/section/1"},{"authorityLevel":"legislation","id":"src-partnership-act-1890-s4","jurisdiction":"United Kingdom","limitations":["Separate Scottish legal personality does not by itself decide the treatment under a particular tax."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["A Scottish firm is a legal person distinct from its partners."],"title":"Partnership Act 1890, section 4","url":"https://www.legislation.gov.uk/ukpga/Vict/53-54/39/section/4"},{"authorityLevel":"legislation","id":"src-companies-act-2006-s16","jurisdiction":"United Kingdom","limitations":["Corporate existence does not settle residence, beneficial ownership, VAT grouping or foreign tax classification."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["Registration forms a body corporate capable of exercising the functions of an incorporated company."],"title":"Companies Act 2006, section 16","url":"https://www.legislation.gov.uk/ukpga/2006/46/section/16"},{"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":"legislation","id":"src-ni-llp-act-2002-s1","jurisdiction":"Northern Ireland","limitations":["This is an origin source, not current standalone law: Companies Act 2006 section 1286 later provided that the Act ceased to have effect."],"publisher":"Northern Ireland Assembly","retrievedAt":"2026-07-28","supports":["Northern Ireland created its own LLP form as a body corporate with legal personality separate from its members."],"title":"Limited Liability Partnerships Act (Northern Ireland) 2002, section 1","url":"https://www.legislation.gov.uk/nia/2002/12/section/1"},{"authorityLevel":"legislation","id":"src-companies-act-2006-s1286","jurisdiction":"United Kingdom","limitations":["Formation date, commencement and transitional provisions still matter for a point-in-time conclusion."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["The Great Britain enactments relating to limited liability partnerships extend to Northern Ireland.","The separate Limited Liability Partnerships Act (Northern Ireland) 2002 ceased to have effect accordingly."],"title":"Companies Act 2006, section 1286","url":"https://www.legislation.gov.uk/ukpga/2006/46/section/1286"},{"authorityLevel":"official-guidance","id":"src-hmrc-pm120100","jurisdiction":"United Kingdom","limitations":["HMRC manuals explain HMRC's view and are not themselves legislation."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A partnership is a relationship and can include natural or artificial persons.","English, Welsh and Northern Irish partnerships lack separate legal personality while Scottish partnerships have it.","A partnership can still be a person for Taxes Acts purposes."],"title":"PM120100: What is a partnership?","url":"https://www.gov.uk/hmrc-internal-manuals/partnership-manual/pm120100"},{"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-intm180010","jurisdiction":"United Kingdom","limitations":["A general HMRC view can vary after examining a specific foreign entity's constitution and facts."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Transparent and opaque are informal labels for who is liable on what income or gains.","The exact UK tax provision must be considered rather than applying one entity-wide label."],"title":"INTM180010: Foreign entity classification","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180010"},{"authorityLevel":"official-guidance","id":"src-hmrc-intm120040","jurisdiction":"United Kingdom","limitations":["Treaty rules and the full statutory exceptions must be checked."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Subject to stated exceptions, a UK-incorporated company is UK resident for corporation tax."],"title":"INTM120040: Company residence incorporation rule","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120040"},{"authorityLevel":"official-guidance","id":"src-hmrc-intm120180","jurisdiction":"United Kingdom","limitations":["Meeting location alone is not conclusive."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Central management and control is a factual inquiry informed by the governing law and constitution."],"title":"INTM120180: Reviewing company residence","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120180"},{"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":"official-guidance","id":"src-hmrc-tsem1563","jurisdiction":"United Kingdom","limitations":["Whether a trust is bare depends on its terms and facts and can require legal advice."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A bare-trust beneficiary with immediate and absolute title is strictly chargeable on the trust income and gains.","Trustees can act administratively without becoming the person strictly charged."],"title":"TSEM1563: Bare trusts","url":"https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem1563"},{"authorityLevel":"official-guidance","id":"src-hmrc-tsem10020","jurisdiction":"United Kingdom","limitations":["The deemed-person rule is tax-specific and does not turn the trust arrangement into a general-law legal person."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["For Income Tax and Capital Gains Tax, trustees of a settlement are treated as a single deemed person distinct from the actual trustees.","The trustee-residence rules and their effective dates must be applied to the settlement and period in question."],"title":"TSEM10020: Trustees as a single person and trustee residence","url":"https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem10020"},{"authorityLevel":"official-guidance","id":"src-hmrc-tsem4200","jurisdiction":"United Kingdom","limitations":["The detailed statutory conditions and exceptions control."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Some settlement income can be treated as the settlor's income."],"title":"TSEM4200: Settlor-interested settlements","url":"https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4200"},{"authorityLevel":"legislation","id":"src-finance-act-2010-charity","jurisdiction":"United Kingdom","limitations":["Charity-law registration and tax recognition are related but not identical classifications."],"publisher":"UK Parliament","retrievedAt":"2026-07-28","supports":["Tax law defines charity, charitable company and charitable trust for the taxes within its scope."],"title":"Finance Act 2010, Part 1","url":"https://www.legislation.gov.uk/ukpga/2010/13/part/1"},{"authorityLevel":"official-guidance","id":"src-charity-tax-exemptions","jurisdiction":"United Kingdom","limitations":["Charity status is not a blanket exemption from every tax or activity."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Charitable-company and charitable-trust exemptions arise under different tax provisions.","Relief is conditional, including on application of income to charitable purposes."],"title":"Tax exemptions for charities","url":"https://www.gov.uk/government/publications/charities-detailed-guidance-notes/annex-i-tax-exemptions-for-charities"},{"authorityLevel":"official-guidance","id":"src-hmrc-vat-groups","jurisdiction":"United Kingdom","limitations":["Eligibility, establishment, control and anti-avoidance conditions must be checked."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Eligible persons can be treated as one taxable person for VAT.","The representative member files and pays for the group while members can remain jointly and severally liable.","Group members keep their separate legal existence."],"title":"Group and divisional registration, VAT Notice 700/2","url":"https://www.gov.uk/guidance/group-and-divisional-registration-vat-notice-7002"},{"authorityLevel":"official-guidance","id":"src-hmrc-vat-partnership-person","jurisdiction":"United Kingdom","limitations":["Scottish partnerships and changes in partner composition require separate treatment."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Partners acting collectively can be treated as a person for VAT even where the firm lacks separate legal personality.","A person acting alone and the same person acting with others in partnership can be different VAT persons."],"title":"VATREG08750: Registration of partnerships","url":"https://www.gov.uk/hmrc-internal-manuals/vat-registration-manual/vatreg08750"},{"authorityLevel":"official-guidance","id":"src-hmrc-branch-pe","jurisdiction":"United Kingdom","limitations":["The existence and profit attribution of a permanent establishment are separate technical questions."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A branch or permanent establishment of a non-resident is not a separate legal person resident in the UK.","The non-resident can still be taxed on income attributable to the UK presence."],"title":"INTM162060: Branches, permanent establishments and residence certificates","url":"https://www.gov.uk/hmrc-internal-manuals/international-manual/intm162060"},{"authorityLevel":"model-standard","id":"src-oecd-model-2017","jurisdiction":"International","limitations":["The applicable bilateral treaty and its current protocol control, not the model alone."],"publisher":"OECD","retrievedAt":"2026-07-28","supports":["Person, residence and permanent establishment are separate treaty concepts.","A permanent establishment is generally a fixed place through which an enterprise's business is carried on.","Treaty treatment of transparent entities depends on how income is treated under relevant domestic law."],"title":"OECD Model Tax Convention 2017","url":"https://www.oecd.org/content/dam/oecd/en/publications/reports/2017/12/model-tax-convention-on-income-and-on-capital-condensed-version-2017_g1g8769b/mtc_cond-2017-en.pdf"},{"authorityLevel":"model-standard","id":"src-oecd-beps-action-7-2015","jurisdiction":"International","limitations":["The actual treaty, multilateral-instrument position, domestic law, effective date and facts control."],"publisher":"OECD","retrievedAt":"2026-07-28","supports":["The 2015 final report proposed treaty changes addressing commissionnaire and similar arrangements, preparatory or auxiliary exceptions, fragmentation and contract splitting.","The work changed the model-standard PE lineage rather than itself creating a UK PE in a private case."],"title":"Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 final report","url":"https://www.oecd.org/en/publications/preventing-the-artificial-avoidance-of-permanent-establishment-status-action-7-2015-final-report_9789264241220-en.html"},{"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":"model-standard","id":"src-fatf-legal-persons-2023","jurisdiction":"International","limitations":["FATF standards require domestic implementation and do not decide a person's tax liability."],"publisher":"Financial Action Task Force","retrievedAt":"2026-07-28","supports":["Beneficial owners are natural persons who ultimately own or control a legal person.","Legal ownership and ultimate beneficial ownership can differ.","Accurate, adequate and up-to-date information needs more than one source."],"title":"Guidance on Beneficial Ownership of Legal Persons","url":"https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf"},{"authorityLevel":"model-standard","id":"src-fatf-legal-arrangements-2024","jurisdiction":"International","limitations":["The governing law and domestic implementation remain decisive."],"publisher":"Financial Action Task Force","retrievedAt":"2026-07-28","supports":["A trust is a legal arrangement governing relationships between parties rather than necessarily a legal person.","Trust roles and ultimate effective control must be kept distinct."],"title":"Guidance on Beneficial Ownership and Transparency of Legal Arrangements","url":"https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf"},{"authorityLevel":"regulation-or-directive","id":"src-eu-vat-directive","jurisdiction":"European Union","limitations":["Member-state implementation and post-exit UK VAT law must be checked for the relevant period."],"publisher":"European Union","retrievedAt":"2026-07-28","supports":["VAT taxable-person status turns on independently carrying on economic activity.","An employee can be outside that independent capacity while having another capacity elsewhere."],"title":"Council Directive 2006/112/EC, Articles 9 and 10","url":"https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32006L0112"},{"authorityLevel":"regulation-or-directive","id":"src-eu-vat-fixed-establishment","jurisdiction":"European Union","limitations":["Different VAT provisions use the definition for different functions.","For a current UK conclusion, check UK VAT law and HMRC's current manuals; this EU instrument is retained here as lineage and comparison."],"publisher":"European Union","retrievedAt":"2026-07-28","supports":["A VAT fixed establishment requires sufficient permanence and suitable human and technical resources for the rule in question.","A VAT identification number alone is insufficient."],"title":"Council Implementing Regulation 282/2011, Article 11","url":"https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32011R0282"},{"authorityLevel":"official-guidance","id":"src-govuk-employment-status","jurisdiction":"United Kingdom","limitations":["The page is general guidance and does not determine a real engagement."],"publisher":"GOV.UK","retrievedAt":"2026-07-28","supports":["One person can be employed and self-employed at the same time.","Employment status for tax is checked for the particular working relationship and can differ from employment-law status."],"title":"Employment status: self-employed and contractor","url":"https://www.gov.uk/employment-status/selfemployed-contractor"},{"authorityLevel":"official-guidance","id":"src-govuk-paye-employers","jurisdiction":"United Kingdom","limitations":["Registration thresholds, worker status, special cases and the rules for the period still need separate checks."],"publisher":"GOV.UK","retrievedAt":"2026-07-28","supports":["An employer normally operates PAYE through payroll to collect Income Tax and National Insurance from employment.","The employer deducts, reports and pays under the payroll rules rather than becoming the employee's income-tax taxpayer."],"title":"PAYE and payroll for employers","url":"https://www.gov.uk/paye-for-employers"},{"authorityLevel":"official-guidance","id":"src-hmrc-vat-guide-700","jurisdiction":"United Kingdom","limitations":["General guidance does not replace the VAT Act, detailed manuals or transaction-specific rules."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["Current UK VAT guidance keeps business and non-business activities separate.","A VAT business is a continuing activity mainly concerned with making supplies to other persons for consideration, with frequency and scale."],"title":"VAT guide, Notice 700","url":"https://www.gov.uk/guidance/vat-guide-notice-700"},{"authorityLevel":"official-guidance","id":"src-hmrc-vat-fixed-establishment","jurisdiction":"United Kingdom","limitations":["The conclusion is provision-specific and fact-specific, and relevant case law and current legislation must also be checked."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["HMRC's current UK view looks for sufficient permanence and human and technical resources for making or receiving the supplies in question.","A registered office or identifier does not by itself settle the fixed-establishment question."],"title":"VATPOSS04500: fixed establishment","url":"https://www.gov.uk/hmrc-internal-manuals/vat-place-of-supply-services/vatposs04500"},{"authorityLevel":"official-guidance","id":"src-irs-entity-classification-2026","jurisdiction":"United States","limitations":["Disregarded treatment has charge-specific exceptions and does not determine UK treatment."],"publisher":"Internal Revenue Service","retrievedAt":"2026-07-28","supports":["Eligible entities can have a federal tax classification different from their state-law form.","A single-owner eligible entity can be disregarded or elect association treatment."],"title":"Classification of taxpayers for US tax purposes","url":"https://www.irs.gov/individuals/international-taxpayers/classification-of-taxpayers-for-us-tax-purposes"},{"authorityLevel":"regulation-or-directive","id":"src-us-check-box-1996","jurisdiction":"United States","limitations":["Later amendments and the current Code and regulations must be checked."],"publisher":"US Department of the Treasury","retrievedAt":"2026-07-28","supports":["The check-the-box entity-classification regulations generally became applicable in 1997."],"title":"Treasury Decision 8697","url":"https://www.govinfo.gov/content/pkg/FR-1996-12-18/pdf/96-31997.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"},{"authorityLevel":"official-guidance","id":"src-hmrc-sole-trader-2026","jurisdiction":"United Kingdom","limitations":["Tax obligations still depend on activities, income, registrations and period."],"publisher":"HM Revenue & Customs","retrievedAt":"2026-07-28","supports":["A sole trader and the business are not separate legal persons.","A trading name does not create a separate person."],"title":"How to set up as a sole trader","url":"https://taxconfident.campaign.gov.uk/small-businesses-and-tax/starting-out/set-up-sole-trader/"}]}