{"collection":"sources","corpusVersion":"2026-07-28.2","count":36,"schema":"taxsorted.uk.tax-identity-collection/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/"}],"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."}