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This guidance note outlines the rules which apply when a partner in a UK partnership is allocated overseas income or profits.

For a discussion of the treatment of income with a UK source, see the Taxation of partnership trading profits and Taxation of other income of a partnership guidance notes. Special rules apply to those partners who access the remittance basis, see the Remittance basis ― overview guidance note.

There are many different sources of overseas income and profits, and the provisions can be complex. This guidance note is only a summary of the rules.

The taxation of UK resident partners in a partnership controlled overseas is outside the scope of this guidance note but more details can be found in Ray: Partnerships, Chapters 16 and 17. Some of the issues are also covered in INTM163130 and guidance is also provided by HMRC Helpsheet HS380.