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UK tax identity ยท law reviewed 28 July 2026

One subject can carry several tax identities at once.

A person, company, relationship, arrangement or tax group can sit in several categories. Legal form is only one axis: attribution, activity, residence, registration, control, reporting and obligations can each point somewhere different. Time, sources and certainty qualify every assertion.

Read the 8 dimensions

The short version

  • Tax identity is a dated vector, not a permanent label.
  • Always name the jurisdiction, tax or reporting regime, activity or capacity, rule set and effective period.
  • Registration numbers are evidence. They do not settle the underlying legal or tax classification.
  • The examples are synthetic teaching records. This page asks for no facts about a real person or organisation and makes no tax decision.

The unit of interpretation

One assertion, one scope, one period.

subject ร— jurisdiction ร— tax/regime ร— activity/context ร— rule set ร— dimension ร— effective time

A complete profile holds several such assertions together. Changing a tax, country, activity, rule set or date may change the answer without changing the underlying subject.

8

Separate dimensions

Each has its own origin, possible values, review triggers and source trail. โ€œUnknownโ€, โ€œconditionalโ€ and โ€œdisputedโ€ remain visible.

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.

Interpretation framework

8 questions before any answer.

Work across the vector instead of guessing from the organisationโ€™s name. Some dimensions allow several simultaneous values because a person can act in more than one capacity or carry more than one obligation.

  1. One value within a stated scope

    Legal existence and form

    What exists under the governing private law?

    Start with the natural person, body, relationship or arrangement created by general law. This is the legal shell, not the whole tax answer.

    Where this category came from

    Company, partnership, trust and association law creates or recognises these categories. Tax law can borrow, override or ignore them for a stated purpose.

    7 possible values
    Natural person
    A human legal person.
    Does not mean: One unchanging tax capacity or one source of income.
    How to set up as a sole trader
    Body corporate
    A separate incorporated legal person.
    Does not mean: Opaque or company-taxed in every jurisdiction and charge.
    Companies Act 2006, section 16 Limited Liability Partnerships Act 2000, section 1 Limited Liability Partnerships Act (Northern Ireland) 2002, section 1
    Unincorporated relationship
    A relationship such as an English general partnership, without separate general-law personality.
    Does not mean: Invisible to tax administration or incapable of filing.
    Partnership Act 1890, section 1 PM120100: What is a partnership?
    Separate firm person
    A firm with distinct legal personality, such as a Scottish partnership.
    Does not mean: Entity-level taxation of its business profits.
    Partnership Act 1890, section 4 PM120100: What is a partnership?
    Legal arrangement
    A relationship governing property and roles, such as a trust.
    Does not mean: One universal trust taxpayer.
    Guidance on Beneficial Ownership and Transparency of Legal Arrangements TSEM10020: Trustees as a single person and trustee residence
    Non-separate presence
    A branch or business presence that is part of another person.
    Does not mean: No local taxing nexus.
    INTM162060: Branches, permanent establishments and residence certificates
    Tax group, not a new legal person
    A grouping that a tax regime treats together.
    Does not mean: The member entities disappear for other law or taxes.
    Group and divisional registration, VAT Notice 700/2

    Evolution recorded here

    • 14 August 1890: Partnership law declared and amended
    • 20 July 2000: Parliament created the Great Britain LLP form
    • 22 November 2002: Northern Ireland created a separate LLP form
    • 8 November 2006: Companies Act 2006 restated the incorporation effect
    • 8 November 2006: Parliament provided for Great Britain LLP legislation to extend to Northern Ireland

    Pause and review when

    • 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.
    Partnership Act 1890, section 1 Partnership Act 1890, section 4 Companies Act 2006, section 16 Limited Liability Partnerships Act 2000, section 1 Limited Liability Partnerships Act (Northern Ireland) 2002, section 1 Companies Act 2006, section 1286 Guidance on Beneficial Ownership and Transparency of Legal Arrangements TSEM10020: Trustees as a single person and trustee residence How to set up as a sole trader INTM162060: Branches, permanent establishments and residence certificates Group and divisional registration, VAT Notice 700/2 PM120100: What is a partnership?

  2. Several values may coexist

    Tax attribution and charge

    For this tax and item, who is treated as earning, owning or disposing?

    Tax can charge the legal person, look through to members, attribute to a beneficiary or settlor, or use a representative member.

    Where this category came from

    Each charging provision defines or implies its own taxpayer and attribution rule. Transparent and opaque are convenient descriptions, not universal properties.

    8 possible values
    Scoped subject charge
    The scoped natural person or legal entity is charged on the relevant item in its own name.
    Does not mean: The subject has one treatment for every item, or that owners have no separate distribution, gain, payroll or reporting consequences.
    INTM180010: Foreign entity classification Tax exemptions for charities
    Member-level attribution
    Members or partners are charged on attributed shares.
    Does not mean: The partnership has no computation, return, VAT or PAYE role.
    PM131450: LLP taxation PM136000: Taxing partnership profits
    Owner-level attribution
    The stated regime looks through a separate legal form and charges its owner on the relevant item.
    Does not mean: The legal entity disappears, another jurisdiction follows the look-through, or every tax uses the same treatment.
    Classification of taxpayers for US tax purposes Help with sharing group structure information
    Beneficiary-level attribution
    The beneficiary is charged on the relevant trust income or gains.
    Does not mean: Every trust is bare or every trust item follows this rule.
    TSEM1563: Bare trusts
    Trustee-level charge
    Trustees are the persons charged or assessed for the stated rule.
    Does not mean: Trustees beneficially own the property.
    TSEM10020: Trustees as a single person and trustee residence
    Settlor attribution
    A settlement rule attributes the item to the settlor.
    Does not mean: The settlor is always charged on trust income.
    TSEM4200: Settlor-interested settlements
    Single VAT taxable person
    Several members are treated together for VAT through a representative member.
    Does not mean: One company for corporation tax or company law.
    Group and divisional registration, VAT Notice 700/2
    Main entity with attributed presence
    The main person remains the taxpayer while profits are attributed to a branch or permanent establishment.
    Does not mean: The presence is a separate resident legal person.
    INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017

    Evolution recorded here

    • 5 July 1994: VAT Act 1994 consolidated VAT grouping rules
    • 1 January 1997: US check-the-box classification became applicable
    • 20 July 2000: Parliament created the Great Britain LLP form
    • 8 April 2010: Finance Act 2010 aligned core tax charity definitions
    • 5 October 2015: BEPS Action 7 strengthened the model PE tests

    Pause and review when

    • 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.
    INTM180010: Foreign entity classification PM131450: LLP taxation PM136000: Taxing partnership profits Classification of taxpayers for US tax purposes Help with sharing group structure information TSEM1563: Bare trusts TSEM10020: Trustees as a single person and trustee residence TSEM4200: Settlor-interested settlements Group and divisional registration, VAT Notice 700/2 INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017 Tax exemptions for charities

  3. Several values may coexist

    Capacity and activity

    In what role is the subject acting for this item or engagement?

    The same person can be an employee, sole trader, landlord, partner, trustee, director, employer and investor at the same time.

    Where this category came from

    Charging rules and case law classify an activity or relationship, not a whole human being for all purposes.

    9 possible values
    Employee
    Acting under an employment relationship for the stated engagement.
    Does not mean: Unable to carry on a separate trade.
    Employment status: self-employed and contractor PM131450: LLP taxation
    Sole trader
    A natural person carrying on business on their own account.
    Does not mean: A separate legal person called the business.
    How to set up as a sole trader
    Partner or LLP member
    Acting as a participant in the partnership business.
    Does not mean: Employment or self-employment status is settled for every rule.
    PM131450: LLP taxation PM136000: Taxing partnership profits
    Salaried LLP member for tax and National Insurance
    An individual LLP member meeting all salaried-member conditions is treated like an employee for the reward, PAYE and Class 1 National Insurance rules.
    Does not mean: The member stops being a member or their chargeable share of LLP profits changes.
    PM131450: LLP taxation
    Company carrying on activity
    The body corporate carries on the stated trade or business.
    Does not mean: Every receipt belongs to the trade or every director acts personally.
    Tax exemptions for charities
    Charitable capacity
    The subject is recognised and acts for charitable purposes within the stated rule.
    Does not mean: All activities and income are exempt.
    Finance Act 2010, Part 1 Tax exemptions for charities
    Trustee
    Holding or administering property under trust duties.
    Does not mean: Beneficial ownership.
    TSEM1563: Bare trusts Guidance on Beneficial Ownership and Transparency of Legal Arrangements
    Beneficiary
    Holding a beneficial interest or entitlement.
    Does not mean: Control, legal title or present tax liability in every trust.
    TSEM1563: Bare trusts Guidance on Beneficial Ownership and Transparency of Legal Arrangements
    Independent economic actor
    Independently carrying on economic activity for the VAT rule.
    Does not mean: Self-employed for every direct-tax or employment-law rule.
    Council Directive 2006/112/EC, Articles 9 and 10 VAT guide, Notice 700

    Evolution recorded here

    • 8 April 2010: Finance Act 2010 aligned core tax charity definitions

    Pause and review when

    • 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.
    How to set up as a sole trader Employment status: self-employed and contractor VAT guide, Notice 700 Council Directive 2006/112/EC, Articles 9 and 10 PM131450: LLP taxation PM136000: Taxing partnership profits Tax exemptions for charities Finance Act 2010, Part 1 TSEM1563: Bare trusts Guidance on Beneficial Ownership and Transparency of Legal Arrangements

  4. Several values may coexist

    Residence and territorial nexus

    Which place claims residence, source or another taxing foothold for this regime?

    Incorporation, residence, domicile, source, permanent establishment, VAT fixed establishment and payroll presence are different connecting tests.

    Where this category came from

    Domestic law first makes residence and source claims; treaties coordinate only their own application; indirect-tax and payroll rules use separate connections.

    6 possible values
    UK domestic resident
    UK domestic law treats the subject as resident for the stated tax and period.
    Does not mean: Exclusive treaty residence or residence for every reporting regime.
    INTM120040: Company residence incorporation rule RDRM20060: Domicile background and the 2025 change TSEM10020: Trustees as a single person and trustee residence
    Dual domestic residence
    More than one jurisdiction's domestic law treats the subject as resident.
    Does not mean: The conflict has been resolved for treaty purposes.
    INTM120180: Reviewing company residence OECD Model Tax Convention 2017
    Treaty-coordinated residence
    An applicable treaty coordinates residence for that treaty.
    Does not mean: The domestic residence claims cease to exist for all law.
    OECD Model Tax Convention 2017
    Permanent establishment
    A direct-tax business presence meeting the relevant domestic or treaty test.
    Does not mean: Subsidiary, registered branch, VAT fixed establishment or separate legal person.
    INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017
    VAT fixed establishment
    A VAT presence with the required permanence and human and technical resources for the rule.
    Does not mean: A VAT number alone or a direct-tax permanent establishment.
    VATPOSS04500: fixed establishment Council Implementing Regulation 282/2011, Article 11
    No separate residence
    The branch, group or arrangement has no independent residence claim in the stated context.
    Does not mean: No local tax or reporting obligation.
    INTM162060: Branches, permanent establishments and residence certificates Group and divisional registration, VAT Notice 700/2

    Evolution recorded here

    • 15 March 1988: UK company residence gained an incorporation rule
    • 5 October 2015: BEPS Action 7 strengthened the model PE tests
    • 6 April 2025: Residence replaced domicile in the reformed personal-tax scope

    Pause and review when

    • 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.
    INTM120040: Company residence incorporation rule INTM120180: Reviewing company residence RDRM20060: Domicile background and the 2025 change TSEM10020: Trustees as a single person and trustee residence INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017 VATPOSS04500: fixed establishment Council Implementing Regulation 282/2011, Article 11 Group and divisional registration, VAT Notice 700/2

  5. Several values may coexist

    Registration, election and grouping

    Which administrative accounts, elections or tax groups apply?

    Registration and elections can create obligations or tax-specific treatment, but a number in a database is not the underlying legal conclusion.

    Where this category came from

    Company, charity and revenue registries, statutory elections and grouping rules create purpose-specific administrative identities.

    8 possible values
    Companies House registration
    The incorporated form is recorded by the company registrar.
    Does not mean: Tax residence, activity or beneficial ownership is proved.
    Companies Act 2006, section 16 Limited Liability Partnerships Act 2000, section 1
    Self Assessment record
    A person or filing unit has a UK Self Assessment administration record.
    Does not mean: Every recorded source is current or correctly classified.
    How to set up as a sole trader PM136000: Taxing partnership profits
    Charity and tax recognition
    Charity-law registration or recognition and HMRC tax recognition have been addressed.
    Does not mean: One registration necessarily supplies the other.
    Finance Act 2010, Part 1 Tax exemptions for charities
    VAT registration
    The stated taxable person is registered or required to register.
    Does not mean: Every cost is business input tax or a fixed establishment exists.
    VAT guide, Notice 700 VATREG08750: Registration of partnerships
    VAT group membership
    Eligible members are treated through one representative registration.
    Does not mean: Corporate or direct-tax consolidation.
    Group and divisional registration, VAT Notice 700/2
    Payroll registration
    An employer or payer operates a payroll reporting account.
    Does not mean: The same subject is the income-tax taxpayer on every profit.
    PM136000: Taxing partnership profits PM131450: LLP taxation PAYE and payroll for employers
    Classification election
    An available election changes a tax classification from an effective date.
    Does not mean: The legal form changes or another jurisdiction follows the election.
    Classification of taxpayers for US tax purposes Treasury Decision 8697
    No registration is determinative
    The current evidence contains no registration that settles the classification.
    Does not mean: No registration duty exists.
    INTM162060: Branches, permanent establishments and residence certificates VATPOSS04500: fixed establishment

    Evolution recorded here

    • 5 July 1994: VAT Act 1994 consolidated VAT grouping rules
    • 1 January 1997: US check-the-box classification became applicable
    • 8 November 2006: Companies Act 2006 restated the incorporation effect
    • 8 November 2006: Parliament provided for Great Britain LLP legislation to extend to Northern Ireland
    • 8 April 2010: Finance Act 2010 aligned core tax charity definitions

    Pause and review when

    • 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.
    Group and divisional registration, VAT Notice 700/2 VATREG08750: Registration of partnerships VAT guide, Notice 700 VATPOSS04500: fixed establishment INTM162060: Branches, permanent establishments and residence certificates Classification of taxpayers for US tax purposes Treasury Decision 8697 Companies Act 2006, section 16 Limited Liability Partnerships Act 2000, section 1 How to set up as a sole trader Tax exemptions for charities Finance Act 2010, Part 1 PM131450: LLP taxation PM136000: Taxing partnership profits PAYE and payroll for employers

  6. Several values may coexist

    Ownership, control and benefit

    Who holds legal title, benefits, exercises formal power or has ultimate effective control?

    Shareholder, member, legal owner, beneficial owner, trustee, beneficiary and controlling person are related roles, not synonyms.

    Where this category came from

    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.

    7 possible values
    Legal owner
    Holds legal title to the interest or property.
    Does not mean: Ultimate benefit or effective control.
    Guidance on Beneficial Ownership of Legal Persons Guidance on Beneficial Ownership and Transparency of Legal Arrangements
    Beneficial owner
    The natural person who ultimately owns or benefits within the stated standard.
    Does not mean: The direct registered holder.
    Guidance on Beneficial Ownership of Legal Persons
    Member or partner
    Participates in the body or relationship under its governing rules.
    Does not mean: Employee, beneficial owner or controlling person in every case.
    Limited Liability Partnerships Act 2000, section 1 PM131450: LLP taxation
    Trustee legal title
    Trustees hold or administer legal title under trust duties.
    Does not mean: The trustees own for their personal benefit.
    Guidance on Beneficial Ownership and Transparency of Legal Arrangements TSEM1563: Bare trusts
    Beneficiary interest
    A person or class has a beneficial interest or entitlement.
    Does not mean: Present control or a presently taxable receipt.
    Guidance on Beneficial Ownership and Transparency of Legal Arrangements TSEM1563: Bare trusts
    Common control
    Members satisfy a tax regime's control connection.
    Does not mean: All activities or liabilities merge.
    Group and divisional registration, VAT Notice 700/2
    CRS controlling person
    A natural person falls within the reporting standard's controlling-person analysis.
    Does not mean: They are automatically the taxpayer or guilty of wrongdoing.
    Consolidated text of the Common Reporting Standard 2025 Guidance on Beneficial Ownership of Legal Persons

    Evolution recorded here

    • 4 March 2022: FATF strengthened legal-person beneficial-ownership standards
    • April 2025: OECD consolidated the amended CRS

    Pause and review when

    • 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.
    Guidance on Beneficial Ownership of Legal Persons Guidance on Beneficial Ownership and Transparency of Legal Arrangements Consolidated text of the Common Reporting Standard 2025 Partnership Act 1890, section 4 Group and divisional registration, VAT Notice 700/2 Limited Liability Partnerships Act 2000, section 1 PM131450: LLP taxation TSEM1563: Bare trusts

  7. Several values may coexist

    Reporting classification

    How does the relevant reporting or due-diligence regime classify the subject?

    CRS, FATCA and other information regimes create their own entity and controlling-person buckets.

    Where this category came from

    International reporting standards and their domestic implementation define purpose-specific classes distinct from income-tax treatment.

    6 possible values
    Individual account holder or reportable person
    The reporting regime treats the subject as an individual.
    Does not mean: No business capacity.
    Consolidated text of the Common Reporting Standard 2025
    Financial Institution
    The subject meets the reporting standard's financial-institution definition.
    Does not mean: A bank in ordinary speech.
    Consolidated text of the Common Reporting Standard 2025
    Active NFE
    The entity meets one of the reporting standard's active non-financial entity tests.
    Does not mean: Active trading for every tax.
    Consolidated text of the Common Reporting Standard 2025
    Passive NFE
    The entity falls within the reporting standard's passive category.
    Does not mean: Tax avoidance or illegality.
    Consolidated text of the Common Reporting Standard 2025
    Trust role reporting
    Settlor, trustee, protector, beneficiary and other control roles are analysed for reporting.
    Does not mean: Every role has the same ownership, control or tax consequence.
    Consolidated text of the Common Reporting Standard 2025 Guidance on Beneficial Ownership and Transparency of Legal Arrangements
    Members remain separately classified
    A tax group does not replace each member's reporting classification.
    Does not mean: Group membership is irrelevant to every report.
    Consolidated text of the Common Reporting Standard 2025 Group and divisional registration, VAT Notice 700/2

    Evolution recorded here

    • April 2025: OECD consolidated the amended CRS

    Pause and review when

    • 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.
    Consolidated text of the Common Reporting Standard 2025 Guidance on Beneficial Ownership of Legal Persons Guidance on Beneficial Ownership and Transparency of Legal Arrangements Group and divisional registration, VAT Notice 700/2

  8. Several values may coexist

    Filing, payment and withholding role

    Who must calculate, return, pay, withhold or report?

    The person who files or remits can differ from the person on whom the underlying income or gain is charged.

    Where this category came from

    Administrative and collection rules assign practical duties to taxpayers, partnerships, trustees, employers, agents and representative members.

    6 possible values
    Taxpayer and filer
    The same subject is charged and files for the stated obligation.
    Does not mean: No agent, withholding or group role.
    How to set up as a sole trader Tax exemptions for charities
    Filing unit, members charged
    The relationship computes or reports while members bear the underlying charge.
    Does not mean: The filing unit is irrelevant.
    PM136000: Taxing partnership profits
    Representative member
    One member accounts for the group under the tax regime.
    Does not mean: Other members lose all liability.
    Group and divisional registration, VAT Notice 700/2
    Employer or withholding role
    The subject deducts, reports or pays amounts connected with another person's income.
    Does not mean: The employer is the employee's income-tax taxpayer.
    PM136000: Taxing partnership profits PM131450: LLP taxation PAYE and payroll for employers
    Trustee administration
    Trustees return, account or pay in an administrative capacity for the stated rule.
    Does not mean: Trustees are always the person strictly chargeable.
    TSEM1563: Bare trusts TSEM10020: Trustees as a single person and trustee residence
    Main entity with PE return
    The non-resident person reports and pays on profits attributed to its local presence.
    Does not mean: The PE is a separately resident company.
    INTM162060: Branches, permanent establishments and residence certificates

    Evolution recorded here

    • 5 July 1994: VAT Act 1994 consolidated VAT grouping rules

    Pause and review when

    • 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.
    PM136000: Taxing partnership profits Group and divisional registration, VAT Notice 700/2 TSEM1563: Bare trusts TSEM10020: Trustees as a single person and trustee residence INTM162060: Branches, permanent establishments and residence certificates How to set up as a sole trader PM131450: LLP taxation Tax exemptions for charities INTM180010: Foreign entity classification PAYE and payroll for employers

Familiar forms, separated roles

10 legal and tax archetypes, viewed across regimes.

These are maps, not lookup-table conclusions. Each role names the regime, the subject and the duty separately.

United Kingdom ยท natural person in business capacity

UK sole trader

One natural person carries on a business; the trading name does not become a second legal person.

Income Tax on trade profits

The natural person ยท Taxpayer and filer

The trade is a separate income source but not a separate legal person.

VAT

The natural person acting as taxable person ยท Registrant if required or elected

All business activities of that registered person normally sit under the registration; business purpose remains item-specific.

Common misreadings
  • 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.
How to set up as a sole trader Employment status: self-employed and contractor VAT guide, Notice 700

England, Wales or Northern Ireland ยท unincorporated business relationship

English, Welsh or Northern Irish general partnership

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.

Income or Corporation Tax on partnership profits

The partners ยท Charged on allocated shares

The partnership computes and returns the business result.

VAT

The partners acting collectively ยท A person for VAT purposes

A change in partners can change the VAT person.

Common misreadings
  • 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.
Partnership Act 1890, section 1 PM120100: What is a partnership? PM136000: Taxing partnership profits VATREG08750: Registration of partnerships

Scotland ยท separate firm with member attribution

Scottish general partnership

The firm has separate legal personality, while business profits can still be attributed to partners under UK tax rules.

Income or Corporation Tax on partnership profits

The partners ยท Charged on allocated shares

Separate Scots-law personality does not force entity-level taxation.

Common misreadings
  • Applying the English legal-personality answer across the UK.
  • Assuming separate personality means opaque taxation.
Partnership Act 1890, section 4 PM120100: What is a partnership? PM136000: Taxing partnership profits

England, Wales and Scotland ยท body corporate with conditional member attribution

Great Britain limited liability partnership

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.

Income and gains

The members ยท Normally charged on their shares

Business-with-a-view-to-profit and winding-up exceptions need separate checks.

PAYE and Class 1 National Insurance

An individual member meeting all salaried-member conditions ยท Employment-treatment overlay for the member's reward

The overlay does not change the amount of that member's chargeable share of LLP profits.

Company-law filings

The LLP ยท Registered body filing accounts and notices

A company-law filing role does not make it a company for the partnership tax provisions.

Common misreadings
  • Treating body corporate and company taxpayer as synonyms.
  • Calling LLP transparency unconditional.
  • Assuming every LLP member has the same employment or National Insurance status.
Limited Liability Partnerships Act 2000, section 1 PM131450: LLP taxation Help with sharing group structure information

Northern Ireland ยท body corporate with territorial lineage

Northern Ireland limited liability partnership lineage

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.

Legal-form history

The Northern Ireland LLP ยท Body corporate under the legislation effective for its period

Formation and transaction dates decide whether the separate 2002 Act or the later UK-wide framework is the relevant origin source.

Income and gains

The members ยท Normally charged on their shares

The same business-with-a-view-to-profit and exception checks remain necessary.

Common misreadings
  • 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.
Limited Liability Partnerships Act (Northern Ireland) 2002, section 1 Companies Act 2006, section 1286 PM131450: LLP taxation

United Kingdom ยท incorporated company

UK private limited company

The company is a body corporate separate from shareholders and directors, with tax residence and activity tested on their own dimensions.

Corporation Tax

The company ยท Taxpayer on its profits and gains

Residence, source, group rules and distributions can create further classifications.

Common misreadings
  • Treating director, shareholder and company as one taxpayer.
  • Treating registered office as proof of actual management.
  • Assuming another jurisdiction follows the UK classification.
Companies Act 2006, section 16 INTM120040: Company residence incorporation rule INTM120180: Reviewing company residence

United Kingdom ยท company with charity status

UK charitable company

One body can simultaneously be a company, a charity and an employer, with tax reliefs conditional on the income, activity and use of funds.

Corporation Tax and charity exemptions

The charitable company ยท Company taxpayer with conditional exemptions

Trading, property, gains and application to charitable purposes must be tested under the relevant provision.

Common misreadings
  • 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.
Companies Act 2006, section 16 Finance Act 2010, Part 1 Tax exemptions for charities

United Kingdom ยท legal arrangement with multiple actors

UK express trust

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.

Bare-trust income and gains

The beneficiary ยท Strictly chargeable where immediate and absolute entitlement exists

Whether the trust is bare is a legal and factual question.

Other settlements

Trustees, settlor or beneficiaries depending on the rule ยท Charge and administration divided by statute

No generic trust-taxpayer answer is safe.

Common misreadings
  • 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.
TSEM1563: Bare trusts TSEM4200: Settlor-interested settlements Guidance on Beneficial Ownership and Transparency of Legal Arrangements Consolidated text of the Common Reporting Standard 2025

United Kingdom ยท tax specific grouping

UK VAT group

Several eligible persons retain their legal identities while VAT treats the group through one representative member as a single taxable person.

VAT

The grouped taxable person through its representative member ยท One return and payment account

Members can remain jointly and severally liable.

Company law and Corporation Tax

Each member company ยท Separate legal and direct-tax subject

VAT grouping does not merge them for other purposes.

Common misreadings
  • 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.
Group and divisional registration, VAT Notice 700/2

United Kingdom and another jurisdiction ยท non separate presence with local nexus

Foreign company with a UK branch or permanent establishment

The foreign company remains the legal person, while a UK presence can create a local charge and profit-attribution exercise.

Corporation Tax on UK permanent-establishment profits

The non-resident company ยท Taxpayer on attributable UK profits

The existence of the PE and the amount attributable to it are separate questions.

Common misreadings
  • 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.
INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017 VATPOSS04500: fixed establishment

Grey areas are relationships

8 places where scoped classifications overlap.

The safer response is not to choose the louder label. Keep both claims, state their scope and ask what fact or rule joins them.

One person, personal and business capacities

There is one legal person, but transactions and expenses still have to be assigned to the correct personal, employment, trading or other capacity.

Classifications that must match

  • Legal existence and form: Natural person
  • Capacity and activity: Sole trader

Scope relations that must hold

  • Legal existence and form: Natural person and Capacity and activity: Sole trader must have the same subject.
  • Legal existence and form: Natural person and Capacity and activity: Sole trader must have the same jurisdiction.

Dangerous shortcut

Creating a fictional second person called the business, or treating every personal item as a business item.

Questions that separate the claims

  • Which activity produced the item?
  • Was the person acting independently or under an employment relationship?
  • Which registration covers the activity?

Pause and review when

  • Mixed employment and self-employment.
  • Shared personal and business assets or expenses.
  • More than one trade or partnership role.

Dimensions: Legal existence and form ยท Capacity and activity ยท Filing, payment and withholding role

How to set up as a sole trader Employment status: self-employed and contractor

Separate body corporate, member-level taxation

The LLP owns, contracts and files as a body corporate while the relevant income and gains are normally attributed to members.

Classifications that must match

  • Legal existence and form: Body corporate
  • Tax attribution and charge: Member-level attribution

Scope relations that must hold

  • Legal existence and form: Body corporate and Tax attribution and charge: Member-level attribution must have different subject.

Dangerous shortcut

Calling the LLP a company taxpayer because it is incorporated, or calling it legally unincorporated because it is transparent.

Questions that separate the claims

  • 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?

Pause and review when

  • Non-profit activity, winding up or temporary cessation.
  • A member may fall within salaried-members rules.
  • Another jurisdiction classifies the LLP.

Dimensions: Legal existence and form ยท Tax attribution and charge ยท Filing, payment and withholding role

Limited Liability Partnerships Act 2000, section 1 PM131450: LLP taxation Help with sharing group structure information

Separate Scottish firm, member-level taxation

Scots law can recognise the firm as a person while UK partnership tax still looks through to partners.

Classifications that must match

  • Legal existence and form: Separate firm person
  • Tax attribution and charge: Member-level attribution

Scope relations that must hold

  • Legal existence and form: Separate firm person and Tax attribution and charge: Member-level attribution must have different subject.
  • Legal existence and form: Separate firm person and Tax attribution and charge: Member-level attribution must have the same jurisdiction.

Dangerous shortcut

Applying either the English legal answer or an entity-level tax answer merely because the firm is a person.

Questions that separate the claims

  • Which UK law territory governs the firm?
  • Which charge and filing duty are in view?

Pause and review when

  • The place of formation or governing law is unclear.
  • The structure includes limited partnerships or cross-border partners.

Dimensions: Legal existence and form ยท Tax attribution and charge

Partnership Act 1890, section 4 PM136000: Taxing partnership profits

Company form and charity status

The company remains a company taxpayer while charity status can provide conditional reliefs for qualifying income and use.

Classifications that must match

  • Legal existence and form: Body corporate
  • Capacity and activity: Charitable capacity
  • Tax attribution and charge: Scoped subject charge

Scope relations that must hold

  • Legal existence and form: Body corporate and Capacity and activity: Charitable capacity must have the same subject.
  • Legal existence and form: Body corporate and Tax attribution and charge: Scoped subject charge must have the same subject.

Dangerous shortcut

Replacing the legal form with charity, or replacing a conditional exemption with tax-free.

Questions that separate the claims

  • Which legal form does the charity use?
  • Is the income from a qualifying activity?
  • Is the income or gain applied to charitable purposes?

Pause and review when

  • Non-primary-purpose trading.
  • Mixed charitable and non-charitable expenditure.
  • Registration and HMRC recognition do not align.

Dimensions: Legal existence and form ยท Capacity and activity ยท Registration, election and grouping ยท Tax attribution and charge

Finance Act 2010, Part 1 Tax exemptions for charities Companies Act 2006, section 16

Separate companies, one VAT taxable person

VAT treats eligible members as one taxable person through a representative member; their company-law and other-tax identities remain separate.

Classifications that must match

  • Legal existence and form: Body corporate
  • Legal existence and form: Tax group, not a new legal person
  • Tax attribution and charge: Single VAT taxable person

Scope relations that must hold

  • Legal existence and form: Body corporate and Legal existence and form: Tax group, not a new legal person must have different subject.
  • Legal existence and form: Tax group, not a new legal person and Tax attribution and charge: Single VAT taxable person must have the same subject.

Dangerous shortcut

Propagating the VAT-group identity to Corporation Tax, CRS, ownership or contracts.

Questions that separate the claims

  • Which bodies were members on the transaction date?
  • Who was the representative member?
  • Does a statutory exception stop an intra-group supply being disregarded?

Pause and review when

  • Membership or representative member changed.
  • Overseas establishments or bought-in services are involved.
  • Joint and several liability matters.

Dimensions: Legal existence and form ยท Tax attribution and charge ยท Registration, election and grouping ยท Filing, payment and withholding role

Group and divisional registration, VAT Notice 700/2

No new legal person, but a local tax presence

The branch or PE is part of the foreign person, yet its local activity can create and measure a local charge.

Classifications that must match

  • Legal existence and form: Non-separate presence
  • Tax attribution and charge: Main entity with attributed presence
  • Residence and territorial nexus: Permanent establishment

Scope relations that must hold

  • Legal existence and form: Non-separate presence and Tax attribution and charge: Main entity with attributed presence must have different subject.
  • Legal existence and form: Non-separate presence and Residence and territorial nexus: Permanent establishment must have the same subject.

Dangerous shortcut

Treating the PE as a resident subsidiary or treating non-separate as non-taxable.

Questions that separate the claims

  • 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?

Pause and review when

  • Remote staff or dependent agents.
  • A subsidiary also performs parent activity.
  • Direct-tax PE and VAT fixed-establishment results differ.

Dimensions: Legal existence and form ยท Residence and territorial nexus ยท Tax attribution and charge

INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017 VATPOSS04500: fixed establishment

Trust legal title, benefit, control and tax attribution

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.

Classifications that must match

  • Legal existence and form: Legal arrangement
  • Ownership, control and benefit: Trustee legal title
  • Ownership, control and benefit: Beneficiary interest

Scope relations that must hold

  • Legal existence and form: Legal arrangement and Ownership, control and benefit: Trustee legal title must have different subject.
  • Legal existence and form: Legal arrangement and Ownership, control and benefit: Beneficiary interest must have different subject.
  • Ownership, control and benefit: Trustee legal title and Ownership, control and benefit: Beneficiary interest must have different subject.

Dangerous shortcut

Naming one universal owner or taxpayer for the trust.

Questions that separate the claims

  • 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?

Pause and review when

  • Bare-trust status is uncertain.
  • Settlor-interest rules may apply.
  • Classes of beneficiaries, protectors or cross-border residence are present.

Dimensions: Legal existence and form ยท Tax attribution and charge ยท Ownership, control and benefit ยท Reporting classification ยท Filing, payment and withholding role

TSEM1563: Bare trusts TSEM4200: Settlor-interested settlements Guidance on Beneficial Ownership and Transparency of Legal Arrangements Consolidated text of the Common Reporting Standard 2025

One legal form, different countries' tax classifications

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.

Classifications that must match

  • Legal existence and form: Body corporate
  • Tax attribution and charge: Scoped subject charge
  • Tax attribution and charge: Owner-level attribution

Scope relations that must hold

  • Legal existence and form: Body corporate and Tax attribution and charge: Scoped subject charge must have the same subject.
  • Tax attribution and charge: Scoped subject charge and Tax attribution and charge: Owner-level attribution must have different subject.
  • Tax attribution and charge: Scoped subject charge and Tax attribution and charge: Owner-level attribution must have different jurisdiction.
  • Tax attribution and charge: Scoped subject charge and Tax attribution and charge: Owner-level attribution must have the same activity or context.

Dangerous shortcut

Forcing one country-wide entity type or treating the mismatch as dirty data.

Questions that separate the claims

  • 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?

Pause and review when

  • A foreign entity, election or disregarded status appears.
  • Payments cross between differently classified entities.
  • Treaty entitlement or hybrid-mismatch rules may matter.

Dimensions: Legal existence and form ยท Tax attribution and charge ยท Residence and territorial nexus ยท Registration, election and grouping

INTM180010: Foreign entity classification Classification of taxpayers for US tax purposes Treasury Decision 8697 Help with sharing group structure information

Category lineage

The categories arrived at different times for different reasons.

This is not a story of one entity taxonomy becoming more precise. Private law, charging rules, administrative groupings and reporting standards added separate layers.

  1. 14 August 1890 ยท codified

    Partnership law declared and amended

    The Partnership Act 1890 put the statutory relationship definition and the Scottish legal-person rule into one Act.

    What stayed separate: Partnership was not invented in 1890, and later tax statutes still decide charge-specific treatment.

    Partnership Act 1890, section 1 Partnership Act 1890, section 4

  2. 15 March 1988 ยท introduced rule

    UK company residence gained an incorporation rule

    The statutory incorporation rule joined the older central-management-and-control doctrine.

    What stayed separate: Management facts and treaty coordination remain relevant; registered office and residence are not synonyms.

    INTM120040: Company residence incorporation rule INTM120180: Reviewing company residence

  3. 5 July 1994 ยท consolidated

    VAT Act 1994 consolidated VAT grouping rules

    The current statutory framework permits eligible persons to be treated together for VAT through a representative member.

    What stayed separate: Members keep separate legal identities and can retain liability.

    Group and divisional registration, VAT Notice 700/2

  4. 1 January 1997 ยท introduced election

    US check-the-box classification became applicable

    Eligible entities gained default and elective US federal tax classifications that can diverge from legal form.

    What stayed separate: The election does not change the state-law entity or compel another country to follow it.

    Treasury Decision 8697 Classification of taxpayers for US tax purposes

  5. 20 July 2000 ยท created form

    Parliament created the Great Britain LLP form

    The LLP Act 2000 created a body corporate with personality separate from its members for England, Wales and Scotland.

    What stayed separate: Northern Ireland initially followed a separate 2002 Act; tax legislation separately supplies normal partnership treatment when its conditions are met.

    Limited Liability Partnerships Act 2000, section 1 PM131450: LLP taxation

  6. 22 November 2002 ยท created form

    Northern Ireland created a separate LLP form

    The Northern Ireland Act created an LLP body corporate with personality separate from its members.

    What stayed separate: This separate Act was later ended when the Great Britain LLP enactments were extended to Northern Ireland.

    Limited Liability Partnerships Act (Northern Ireland) 2002, section 1

  7. 8 November 2006 ยท consolidated

    Companies Act 2006 restated the incorporation effect

    The current company-law framework states that registration forms the body corporate.

    What stayed separate: Tax, charity, reporting and control overlays remain separate questions.

    Companies Act 2006, section 16

  8. 8 November 2006 ยท consolidated

    Parliament provided for Great Britain LLP legislation to extend to Northern Ireland

    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.

    What stayed separate: Point-in-time work still needs formation, commencement and transitional facts.

    Companies Act 2006, section 1286 Limited Liability Partnerships Act (Northern Ireland) 2002, section 1

  9. 8 April 2010 ยท consolidated

    Finance Act 2010 aligned core tax charity definitions

    Tax legislation supplied cross-tax definitions of charity, charitable company and charitable trust.

    What stayed separate: The legal form and the conditions of each relief still matter.

    Finance Act 2010, Part 1 Tax exemptions for charities

  10. 5 October 2015 ยท strengthened standard

    BEPS Action 7 strengthened the model PE tests

    The OECD final report proposed changes addressing commissionnaire arrangements, preparatory or auxiliary exceptions, fragmentation and contract splitting.

    What stayed separate: A model-standard change does not itself create a UK PE; the actual treaty, domestic law, effective date and facts remain controlling.

    Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 final report OECD Model Tax Convention 2017

  11. 4 March 2022 ยท strengthened standard

    FATF strengthened legal-person beneficial-ownership standards

    Revised Recommendation 24 strengthened access to adequate, accurate and up-to-date natural-person ownership and control information.

    What stayed separate: Beneficial ownership remains distinct from legal title, tax liability and guilt.

    Guidance on Beneficial Ownership of Legal Persons

  12. 6 April 2025 ยท changed connecting factor

    Residence replaced domicile in the reformed personal-tax scope

    HMRC states that from 6 April 2025 domicile ceased to be the relevant connecting factor in the changed regime and residence-based rules apply.

    What stayed separate: Domicile remains relevant to historical periods and must not be silently erased.

    RDRM20060: Domicile background and the 2025 change

  13. April 2025 ยท consolidated standard

    OECD consolidated the amended CRS

    The consolidation brings the original and amended reporting classifications and controlling-person rules together.

    What stayed separate: Domestic adoption and later exchange dates govern actual obligations.

    Consolidated text of the Common Reporting Standard 2025

Worked examples ยท no real people

7 synthetic profiles show the vector in motion.

Every assertion names its subject, jurisdiction, tax or regime, activity, rule set, status, effective-date basis and sources. Open a profile to see what is supported and what the framework deliberately leaves undecided.

Synthetic ยท as at 28 July 2026Employee with a separate sole tradeA synthetic UK-resident individual works under an employment contract and also carries on a design trade on their own account.

Subjects in this example

  • Synthetic individual ยท natural person
  • Synthetic employer ยท employer

Legal and tax archetypes

  • UK sole trader

Legal existence and form ยท established

Natural person

The person and sole trade are not separate legal persons.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
General law
Activity or context
Personal, employment and sole-trade capacities
Rule set
UK general law and HMRC sole-trader guidance as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

How to set up as a sole trader

Tax attribution and charge ยท established

Scoped subject charge

The natural person is charged on their employment and trade income under the respective rules.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Income Tax
Activity or context
Employment income and independent design-trade profits
Rule set
UK Income Tax rules and HMRC sole-trader guidance as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

How to set up as a sole trader

Capacity and activity ยท established

Employee

Synthetic assumption limited to the employment engagement.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Employment status for tax
Activity or context
Synthetic employment engagement
Rule set
GOV.UK employment-status guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

Employment status: self-employed and contractor

Capacity and activity ยท established

Sole trader

Synthetic assumption limited to the independent design trade.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Income Tax
Activity or context
Independent design trade
Rule set
HMRC sole-trader guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

How to set up as a sole trader

Residence and territorial nexus ยท established

UK domestic resident

Synthetic example assumption, not a residence assessment.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Income Tax residence
Activity or context
2026-27 tax year synthetic assumption
Rule set
UK residence-based personal-tax framework as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

RDRM20060: Domicile background and the 2025 change

Registration, election and grouping ยท conditional

Self Assessment record

The example assumes the trade requires a Self Assessment return.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Self Assessment
Activity or context
Independent design trade
Rule set
HMRC sole-trader administration guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

How to set up as a sole trader

Ownership, control and benefit ยท established

Legal owner

The example contains no separate body or nominee.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
General law
Activity or context
Synthetic design-trade assets
Rule set
HMRC sole-trader guidance as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

How to set up as a sole trader

Reporting classification ยท conditional

Individual account holder or reportable person

Reporting classification remains account and regime specific.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Taxpayer and filer

The individual files their own assumed return; the employer separately withholds on employment pay.

Assertion scope
Subject
Synthetic individual
Jurisdiction
United Kingdom
Tax or regime
Self Assessment
Activity or context
Independent design-trade return
Rule set
HMRC sole-trader administration guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

How to set up as a sole trader

Filing, payment and withholding role ยท established

Employer or withholding role

The synthetic employer operates withholding for the employment engagement; it is not the taxpayer on the individual's trade profits.

Assertion scope
Subject
Synthetic employer
Jurisdiction
United Kingdom
Tax or regime
PAYE
Activity or context
Synthetic employment engagement
Rule set
GOV.UK employment-status guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

PAYE and payroll for employers

Needs review

  • 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.

Not determined

  • Employment status from real contract facts.
  • Allowable expenses, VAT registration or MTD eligibility.
  • Any amount of tax.
Read this example as JSON
Synthetic ยท as at 28 July 2026Great Britain consulting LLP with two differently treated membersA 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.

Subjects in this example

  • Synthetic Great Britain LLP ยท limited liability partnership
  • Synthetic LLP member A ยท natural person member
  • Synthetic salaried LLP member B ยท natural person member

Legal and tax archetypes

  • Great Britain limited liability partnership

Legal existence and form ยท established

Body corporate

The LLP is incorporated under the 2000 Act.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
Great Britain
Tax or regime
General law
Activity or context
LLP incorporation and separate personality
Rule set
Limited Liability Partnerships Act 2000 section 1

Effective-date basis: stated interval. Stated interval from 6 April 2001 with no stated end.

Limited Liability Partnerships Act 2000, section 1

Tax attribution and charge ยท conditional

Member-level attribution

The synthetic facts state a business carried on with a view to profit.

Assertion scope
Subject
Synthetic LLP member A
Jurisdiction
United Kingdom
Tax or regime
Income Tax on LLP profits
Activity or context
Member A's share of the consulting business profits
Rule set
ITTOIA 2005 section 863 and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

PM131450: LLP taxation

Tax attribution and charge ยท conditional

Member-level attribution

The salaried-member overlay does not change the amount of member B's chargeable LLP profit share.

Assertion scope
Subject
Synthetic salaried LLP member B
Jurisdiction
United Kingdom
Tax or regime
Income Tax on LLP profits
Activity or context
Member B's chargeable share of the consulting business profits
Rule set
ITTOIA 2005 sections 863 and 863A and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

PM131450: LLP taxation

Capacity and activity ยท established

Partner or LLP member

The example concerns registered members acting in the LLP business.

Assertion scope
Subject
Synthetic LLP member A
Jurisdiction
Great Britain
Tax or regime
LLP membership
Activity or context
Member A acting in the consulting business
Rule set
LLP Act 2000 and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

PM131450: LLP taxation

Capacity and activity ยท established

Salaried LLP member for tax and National Insurance

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.

Assertion scope
Subject
Synthetic salaried LLP member B
Jurisdiction
United Kingdom
Tax or regime
PAYE and Class 1 National Insurance
Activity or context
Member B's reward for services as an LLP member
Rule set
ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

PM131450: LLP taxation

Residence and territorial nexus ยท unknown

UK domestic resident

Incorporation and a UK office do not settle every member or treaty residence question.

Assertion scope
Subject
Synthetic LLP member A
Jurisdiction
United Kingdom
Tax or regime
Income Tax residence
Activity or context
Member A's 2026-27 tax year
Rule set
UK domestic residence rules as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 to 5 April 2027.

RDRM20060: Domicile background and the 2025 change

Registration, election and grouping ยท established

Companies House registration

Incorporation supplies the company-registry identity.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
Great Britain
Tax or regime
Companies House registration
Activity or context
LLP incorporation
Rule set
Limited Liability Partnerships Act 2000

Effective-date basis: stated interval. Stated interval from 6 April 2001 with no stated end.

Limited Liability Partnerships Act 2000, section 1

Ownership, control and benefit ยท established

Member or partner

The synthetic subjects are registered LLP members.

Assertion scope
Subject
Synthetic LLP member A
Jurisdiction
Great Britain
Tax or regime
LLP membership
Activity or context
Registered membership in the synthetic LLP
Rule set
LLP Act 2000 and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

PM131450: LLP taxation

Reporting classification ยท unknown

Financial Institution

No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Active NFE

No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Passive NFE

No account, income, asset or controlling-person facts were supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Filing unit, members charged

The LLP computes and reports partnership results while members are normally charged.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
United Kingdom
Tax or regime
Partnership return
Activity or context
Consulting business profit computation and return
Rule set
HMRC partnership-tax guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

PM136000: Taxing partnership profits

Filing, payment and withholding role ยท established

Employer or withholding role

The LLP operates PAYE and Class 1 National Insurance for member B's reward without changing the member-level attribution of chargeable LLP profits.

Assertion scope
Subject
Synthetic Great Britain LLP
Jurisdiction
United Kingdom
Tax or regime
PAYE and Class 1 National Insurance
Activity or context
Member B's salaried-member reward
Rule set
ITTOIA 2005 section 863A and HMRC PM131450 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 6 April 2026 with no stated end.

PM131450: LLP taxation

Needs review

  • 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.

Not determined

  • Member profit shares or liabilities.
  • Foreign, treaty, CRS, VAT or payroll treatment.
Read this example as JSON
Synthetic ยท as at 28 July 2026Charitable company with trading incomeA synthetic UK company limited by guarantee is registered as a charity and receives trading income.

Subjects in this example

  • Synthetic charitable company ยท company limited by guarantee
  • Synthetic guarantee members ยท member class

Legal and tax archetypes

  • UK charitable company

Legal existence and form ยท established

Body corporate

The company is incorporated.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Company limited by guarantee
Rule set
Companies Act 2006 section 16

Effective-date basis: stated interval. Stated interval from 10 January 2024 with no stated end.

Companies Act 2006, section 16

Tax attribution and charge ยท established

Scoped subject charge

The charitable company remains the company taxpayer before applying relief provisions.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax and charity exemptions
Activity or context
Synthetic trading income before relief conditions
Rule set
Finance Act 2010 charity framework and HMRC charity guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 10 January 2024 with no stated end.

Tax exemptions for charities

Capacity and activity ยท established

Charitable capacity

The synthetic example assumes charity-law and HMRC recognition.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Charity tax recognition
Activity or context
Recognised charitable purposes
Rule set
Finance Act 2010 Part 1

Effective-date basis: stated interval. Stated interval from 1 March 2024 with no stated end.

Finance Act 2010, Part 1

Capacity and activity ยท established

Company carrying on activity

The company receives trading income.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax and charity exemptions
Activity or context
Synthetic trading activity
Rule set
HMRC charity tax-exemption guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Tax exemptions for charities

Residence and territorial nexus ยท conditional

UK domestic resident

UK incorporation supplies the normal domestic rule, subject to treaty exceptions.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax residence
Activity or context
UK-incorporated company
Rule set
UK incorporation residence rule and treaty exceptions as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 10 January 2024 with no stated end.

INTM120040: Company residence incorporation rule

Registration, election and grouping ยท established

Charity and tax recognition

Both recognition layers are synthetic assumptions.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Charity-law and HMRC tax recognition
Activity or context
Synthetic recognised charity
Rule set
Finance Act 2010 Part 1 and applicable charity-law recognition

Effective-date basis: stated interval. Stated interval from 1 March 2024 with no stated end.

Finance Act 2010, Part 1

Ownership, control and benefit ยท established

Member or partner

The company has members under its company form; the example makes no personal beneficial-ownership claim.

Assertion scope
Subject
Synthetic guarantee members
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Guarantee membership
Rule set
Companies Act 2006 and synthetic articles

Effective-date basis: stated interval. Stated interval from 10 January 2024 with no stated end.

Companies Act 2006, section 16

Reporting classification ยท conditional

Active NFE

Some qualifying non-profit entities can meet an Active NFE route, but the exact conditions and account facts must be checked.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Qualifying non-profit Active NFE route for a hypothetical account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Taxpayer and filer

The company claims any available exemption in its company tax position.

Assertion scope
Subject
Synthetic charitable company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax
Activity or context
Company tax position for synthetic trading income
Rule set
HMRC charity tax-exemption guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Tax exemptions for charities

Needs review

  • 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.

Not determined

  • Whether the trading income is exempt.
  • Any Corporation Tax amount.
  • The real organisation's owners, controllers or CRS class.
Read this example as JSON
Synthetic ยท as at 28 July 2026Three companies in one UK VAT groupThree synthetic UK companies under common control have an approved VAT group with one representative member.

Subjects in this example

  • Synthetic VAT group ยท vat group
  • Synthetic representative company ยท company
  • Synthetic member company B ยท company
  • Synthetic member company C ยท company

Legal and tax archetypes

  • UK VAT group
  • UK private limited company

Legal existence and form ยท established

Tax group, not a new legal person

The VAT grouping does not create a fourth company.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT
Activity or context
Approved VAT grouping
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Legal existence and form ยท established

Body corporate

The representative member remains a separate incorporated company.

Assertion scope
Subject
Synthetic representative company
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Representative member's separate incorporation
Rule set
Companies Act 2006 section 16

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Companies Act 2006, section 16 Group and divisional registration, VAT Notice 700/2

Legal existence and form ยท established

Body corporate

VAT grouping does not end member B's separate company identity.

Assertion scope
Subject
Synthetic member company B
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Member B's separate incorporation
Rule set
Companies Act 2006 section 16

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Companies Act 2006, section 16 Group and divisional registration, VAT Notice 700/2

Legal existence and form ยท established

Body corporate

VAT grouping does not end member C's separate company identity.

Assertion scope
Subject
Synthetic member company C
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Member C's separate incorporation
Rule set
Companies Act 2006 section 16

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Companies Act 2006, section 16 Group and divisional registration, VAT Notice 700/2

Tax attribution and charge ยท established

Single VAT taxable person

The approved group is treated through one representative member for VAT.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT
Activity or context
Supplies made while all three companies are members
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Capacity and activity ยท conditional

Independent economic actor

The example assumes business activities within the VAT grouping rules.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT taxable-person rules
Activity or context
Grouped economic activities
Rule set
UK VAT guidance as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

VAT guide, Notice 700

Residence and territorial nexus ยท established

No separate residence

The VAT group has no separate residence from its members.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT grouping
Activity or context
Tax-specific group identity
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Registration, election and grouping ยท established

VAT group membership

The example assumes approved membership and representative member.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT registration
Activity or context
Approved group membership and representative member
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Ownership, control and benefit ยท established

Common control

The synthetic companies meet the relevant control condition.

Assertion scope
Subject
Synthetic VAT group
Jurisdiction
United Kingdom
Tax or regime
VAT group eligibility
Activity or context
Control connection among the three member companies
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Reporting classification ยท established

Members remain separately classified

VAT grouping does not replace each company's classification under other regimes.

Assertion scope
Subject
Synthetic representative company
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Effect of VAT grouping on member reporting classes
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Representative member

The representative member submits the single VAT return and handles payment or repayment.

Assertion scope
Subject
Synthetic representative company
Jurisdiction
United Kingdom
Tax or regime
VAT
Activity or context
Single VAT return and payment account for the group
Rule set
VAT Notice 700/2 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 April 2026 with no stated end.

Group and divisional registration, VAT Notice 700/2

Needs review

  • 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.

Not determined

  • Eligibility or approval of any real VAT group.
  • VAT due or recoverable.
  • Corporation Tax, CRS or beneficial ownership of any member.
Read this example as JSON
Synthetic ยท as at 28 July 2026Foreign company with a UK permanent establishmentA synthetic non-UK company carries on part of its business through a UK office that the example assumes meets the applicable PE test.

Subjects in this example

  • Synthetic foreign company ยท company
  • Synthetic UK office and business presence ยท non separate presence

Legal and tax archetypes

  • Foreign company with a UK branch or permanent establishment

Legal existence and form ยท established

Non-separate presence

The UK branch is part of the foreign company, not a subsidiary.

Assertion scope
Subject
Synthetic UK office and business presence
Jurisdiction
United Kingdom
Tax or regime
General law and Corporation Tax
Activity or context
UK office of the foreign company
Rule set
HMRC INTM162060 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

INTM162060: Branches, permanent establishments and residence certificates

Tax attribution and charge ยท established

Main entity with attributed presence

The foreign company remains the taxpayer on profits attributed to the UK PE.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax on PE-attributable profits
Activity or context
Profits attributed to the synthetic UK office
Rule set
Applicable UK law and treaty PE attribution rules as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

INTM162060: Branches, permanent establishments and residence certificates OECD Model Tax Convention 2017

Capacity and activity ยท established

Company carrying on activity

The synthetic office carries on part of the company's trade.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom
Tax or regime
Direct-tax business activity
Activity or context
Trade carried on partly through the UK office
Rule set
Applicable UK law and bilateral treaty as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

OECD Model Tax Convention 2017

Residence and territorial nexus ยท conditional

Permanent establishment

The example assumes the applicable domestic and treaty tests are met.

Assertion scope
Subject
Synthetic UK office and business presence
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax and bilateral treaty
Activity or context
Fixed UK office through which business is carried on
Rule set
Applicable UK domestic rule and actual treaty; OECD Model 2017 is comparison only

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

OECD Model Tax Convention 2017

Residence and territorial nexus ยท unknown

VAT fixed establishment

The direct-tax PE assumption does not settle the separate VAT fixed-establishment test.

Assertion scope
Subject
Synthetic UK office and business presence
Jurisdiction
United Kingdom
Tax or regime
VAT place of supply
Activity or context
Whether the UK office has suitable permanent human and technical resources
Rule set
HMRC VATPOSS04500 as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

VATPOSS04500: fixed establishment

Registration, election and grouping ยท established

No registration is determinative

Registration evidence alone does not establish the PE.

Assertion scope
Subject
Synthetic UK office and business presence
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax permanent establishment
Activity or context
Branch and tax registration evidence
Rule set
HMRC INTM162060 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

INTM162060: Branches, permanent establishments and residence certificates

Ownership, control and benefit ยท unknown

Beneficial owner

The example contains no shareholder or ultimate-control facts.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
Foreign formation jurisdiction and United Kingdom
Tax or regime
Beneficial ownership
Activity or context
Natural-person ownership and control graph
Rule set
FATF legal-person guidance subject to domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Guidance on Beneficial Ownership of Legal Persons

Reporting classification ยท unknown

Financial Institution

The example supplies no account, activity or reporting facts; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom and foreign residence jurisdictions
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Active NFE

The example supplies no account, activity or reporting facts; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom and foreign residence jurisdictions
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Passive NFE

The example supplies no account, activity or reporting facts; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom and foreign residence jurisdictions
Tax or regime
Common Reporting Standard
Activity or context
Hypothetical financial account
Rule set
OECD CRS 2025 subject to domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Main entity with PE return

The non-resident company reports the profits attributed to its UK presence.

Assertion scope
Subject
Synthetic foreign company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax
Activity or context
Return of profits attributed to the UK PE
Rule set
HMRC INTM162060 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 October 2025 with no stated end.

INTM162060: Branches, permanent establishments and residence certificates

Needs review

  • Read the actual treaty and domestic rule.
  • Separate PE existence from profit attribution.
  • Assess VAT fixed establishment, payroll and branch registration independently.

Not determined

  • Whether a real PE exists.
  • Profits attributable to a PE.
  • VAT, payroll, residence, ownership or reporting outcomes.
Read this example as JSON
Synthetic ยท as at 28 July 2026Bare trust with an absolutely entitled adult beneficiaryA synthetic English-law bare trust has trustees holding legal title and one adult beneficiary with immediate and absolute title to capital and income.

Subjects in this example

  • Synthetic bare-trust arrangement ยท legal arrangement
  • Synthetic trustees acting together ยท trustee body
  • Synthetic absolutely entitled adult beneficiary ยท natural person beneficiary

Legal and tax archetypes

  • UK express trust

Legal existence and form ยท established

Legal arrangement

The trust is a relationship governing property and roles.

Assertion scope
Subject
Synthetic bare-trust arrangement
Jurisdiction
England and Wales
Tax or regime
Trust law
Activity or context
Property held on synthetic bare-trust terms
Rule set
English trust law and FATF legal-arrangement model as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

Guidance on Beneficial Ownership and Transparency of Legal Arrangements

Tax attribution and charge ยท conditional

Beneficiary-level attribution

The example assumes immediate and absolute entitlement satisfying the bare-trust treatment.

Assertion scope
Subject
Synthetic absolutely entitled adult beneficiary
Jurisdiction
United Kingdom
Tax or regime
Income Tax and Capital Gains Tax
Activity or context
Income and gains from the bare-trust property
Rule set
HMRC TSEM1563 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

TSEM1563: Bare trusts

Capacity and activity ยท established

Trustee

The trustees hold and administer the legal title.

Assertion scope
Subject
Synthetic trustees acting together
Jurisdiction
England and Wales
Tax or regime
Trust law
Activity or context
Holding and administering legal title
Rule set
Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

TSEM1563: Bare trusts

Capacity and activity ยท established

Beneficiary

The synthetic adult has immediate and absolute beneficial entitlement.

Assertion scope
Subject
Synthetic absolutely entitled adult beneficiary
Jurisdiction
England and Wales
Tax or regime
Trust law
Activity or context
Immediate and absolute entitlement to capital and income
Rule set
Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

TSEM1563: Bare trusts

Residence and territorial nexus ยท unknown

UK domestic resident

No trustee, settlor or beneficiary residence facts are supplied.

Assertion scope
Subject
Synthetic trustees acting together
Jurisdiction
United Kingdom
Tax or regime
Trustee residence for Income Tax and Capital Gains Tax
Activity or context
Deemed trustee body for the synthetic settlement
Rule set
HMRC TSEM10020 as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

TSEM10020: Trustees as a single person and trustee residence

Registration, election and grouping ยท established

No registration is determinative

Registration does not decide beneficial entitlement or the person charged.

Assertion scope
Subject
Synthetic bare-trust arrangement
Jurisdiction
United Kingdom
Tax or regime
Trust administration
Activity or context
Effect of registration on beneficial entitlement and attribution
Rule set
HMRC TSEM1563 as at 2026-07-28

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

TSEM1563: Bare trusts

Ownership, control and benefit ยท established

Trustee legal title

Trustees hold legal title under the synthetic arrangement.

Assertion scope
Subject
Synthetic trustees acting together
Jurisdiction
England and Wales
Tax or regime
Trust ownership
Activity or context
Legal title to the trust property
Rule set
Synthetic trust terms and FATF legal-arrangement guidance

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

Guidance on Beneficial Ownership and Transparency of Legal Arrangements

Ownership, control and benefit ยท established

Beneficiary interest

The beneficiary has immediate and absolute beneficial entitlement.

Assertion scope
Subject
Synthetic absolutely entitled adult beneficiary
Jurisdiction
England and Wales
Tax or regime
Trust ownership
Activity or context
Immediate and absolute beneficial interest
Rule set
Synthetic trust terms and HMRC TSEM1563 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

TSEM1563: Bare trusts

Reporting classification ยท conditional

Trust role reporting

CRS analysis names trust roles separately; actual reporting depends on the account and domestic implementation.

Assertion scope
Subject
Synthetic bare-trust arrangement
Jurisdiction
United Kingdom
Tax or regime
Common Reporting Standard
Activity or context
Trust-role analysis for a hypothetical financial account
Rule set
OECD CRS 2025 subject to UK implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท conditional

Trustee administration

Trustees may act administratively even where the beneficiary is strictly chargeable.

Assertion scope
Subject
Synthetic trustees acting together
Jurisdiction
United Kingdom
Tax or regime
Income Tax and Capital Gains Tax administration
Activity or context
Administrative action for income and gains strictly chargeable on the beneficiary
Rule set
HMRC TSEM1563 as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 June 2022 with no stated end.

TSEM1563: Bare trusts

Needs review

  • 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.

Not determined

  • The legal effect of a real trust instrument.
  • Residence or reporting obligations.
  • Any tax liability, return requirement or beneficial-owner record.
Read this example as JSON
Synthetic ยท as at 28 July 2026UK company with a different US federal tax classificationA 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.

Subjects in this example

  • Synthetic UK company ยท private limited company
  • Synthetic sole natural-person owner ยท natural person owner

Legal and tax archetypes

  • UK private limited company

Legal existence and form ยท established

Body corporate

The UK company remains a body corporate separate from its sole owner.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom
Tax or regime
Company law
Activity or context
Synthetic company incorporation
Rule set
Companies Act 2006 section 16

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

Companies Act 2006, section 16 Help with sharing group structure information

Tax attribution and charge ยท established

Scoped subject charge

The incorporated company is the UK Corporation Tax subject for the synthetic trade.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax
Activity or context
Synthetic software trade profits
Rule set
UK company-tax treatment as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

Help with sharing group structure information INTM180010: Foreign entity classification

Tax attribution and charge ยท conditional

Owner-level attribution

The example assumes a valid owner-level US federal classification; it does not ask the UK to follow that classification.

Assertion scope
Subject
Synthetic sole natural-person owner
Jurisdiction
United States
Tax or regime
US federal income tax
Activity or context
Synthetic software trade profits
Rule set
US entity-classification rules and the synthetic valid classification as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 January 2025 with no stated end.

Classification of taxpayers for US tax purposes Help with sharing group structure information

Capacity and activity ยท established

Company carrying on activity

The company, rather than its owner acting personally, carries on the synthetic trade under UK law.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax
Activity or context
Synthetic software trade
Rule set
UK Corporation Tax framework as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

Help with sharing group structure information

Residence and territorial nexus ยท conditional

UK domestic resident

UK incorporation supplies the normal domestic residence rule, subject to statutory and treaty exceptions.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax residence
Activity or context
UK-incorporated synthetic company
Rule set
UK incorporation residence rule and treaty exceptions as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

INTM120040: Company residence incorporation rule

Registration, election and grouping ยท conditional

Classification election

The example assumes an available and valid US election from the stated date; the election does not change the UK legal form.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United States
Tax or regime
US federal entity classification
Activity or context
Synthetic valid classification election
Rule set
US check-the-box rules as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 January 2025 with no stated end.

Classification of taxpayers for US tax purposes Treasury Decision 8697

Ownership, control and benefit ยท established

Beneficial owner

The synthetic facts state one natural-person ultimate owner; this role is separate from both countries' tax-attribution results.

Assertion scope
Subject
Synthetic sole natural-person owner
Jurisdiction
United Kingdom
Tax or regime
Beneficial ownership
Activity or context
Synthetic sole ownership and ultimate control
Rule set
FATF legal-person guidance subject to UK implementation

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

Guidance on Beneficial Ownership of Legal Persons

Reporting classification ยท unknown

Financial Institution

No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom and United States
Tax or regime
CRS and FATCA
Activity or context
Hypothetical financial account
Rule set
Applicable reporting regime and domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Active NFE

No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom and United States
Tax or regime
CRS and FATCA
Activity or context
Hypothetical financial account
Rule set
Applicable reporting regime and domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Reporting classification ยท unknown

Passive NFE

No account, income, asset or reporting-implementation facts are supplied; Financial Institution, Active NFE and Passive NFE remain the live candidates.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom and United States
Tax or regime
CRS and FATCA
Activity or context
Hypothetical financial account
Rule set
Applicable reporting regime and domestic implementation

Effective-date basis: current at corpus review. Current at the corpus review on 28 July 2026; no earlier interval is claimed.

Consolidated text of the Common Reporting Standard 2025

Filing, payment and withholding role ยท established

Taxpayer and filer

The company remains the UK taxpayer and filer even though the US federal attribution in this example points to its owner.

Assertion scope
Subject
Synthetic UK company
Jurisdiction
United Kingdom
Tax or regime
Corporation Tax
Activity or context
Synthetic software trade return
Rule set
UK Corporation Tax framework as at 2026-07-28

Effective-date basis: stated interval. Stated interval from 1 February 2024 with no stated end.

Help with sharing group structure information

Needs review

  • 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.

Not determined

  • 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.
Read this example as JSON

Method and boundaries

Preserve scope, uncertainty and history.

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.

Editorial rules

  1. Never collapse legal form, taxable person, reporting person and beneficial owner into one label.
  2. Every assertion states subjectRef, jurisdiction, taxOrRegime, activityOrContext, ruleset, status and an effective-date basis.
  3. Treat identifiers and registrations as evidence, not as proof of the underlying classification.
  4. Keep unknown, conditional, disputed and not-applicable distinct.
  5. Model a branch, permanent establishment or VAT fixed establishment as a nexus overlay unless local law creates a separate legal person.
  6. A model convention or international standard is not enacted domestic law or the text of an actual treaty.
  7. A change creates a new effective-dated assertion; it does not rewrite the earlier one.
  8. 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.

Hard 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.

Deliberate gaps are part of the answer

intentionally not generalised

No universal legal-form equivalence

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.

Safe next step: Read the foreign governing law, constitutional documents and the applying jurisdiction's classification rule.

coverage gap

No all-tax outcome table

A form-by-tax table would falsely imply that the form alone determines each outcome.

Safe next step: Assess the exact charge, item, capacity, jurisdiction and period.

coverage gap

No bilateral-treaty result

The OECD Model explains concepts but actual treaties and protocols differ.

Safe next step: Read the current treaty text and domestic implementation for both states.

privacy boundary

No natural-person ownership or control graph

Beneficial ownership can be sensitive personal data and this public corpus contains only roles and synthetic examples.

Safe next step: Keep verified private records in an approved matter or compliance system with access controls.

effect boundary

No hosted personal classification

This release is a public framework and synthetic interpreter. It accepts no private facts and makes no authority-facing decision.

Safe next step: Use the schema locally, retain sources and facts, and obtain qualified review for consequential cases.

method boundary

No numerical legal confidence

A percentage would hide whether the gap is law, evidence, dates, jurisdiction or contested authority.

Safe next step: Report missing facts, competing classifications, source authority and a plain review reason.

coverage gap

Community interest companies not yet modelled

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.

Safe next step: Add CIC legislation, regulator status, company-tax treatment, control and activity-specific examples before classifying one.

coverage gap

Charitable incorporated organisations not yet modelled

A CIO is an incorporated charity form without the same Companies Act identity as a charitable company.

Safe next step: Add separate England and Wales, Scotland and Northern Ireland form and tax sources rather than mapping a CIO to a company by name.

coverage gap

Limited partnerships not yet modelled

General partners, limited partners, Scottish legal personality, private-fund rules and registration changes require more than the general-partnership archetypes.

Safe next step: Model each territorial form, partner role, charge and effective period from the Limited Partnerships Act and current tax guidance.

coverage gap

Mutuals not yet modelled

Co-operative societies, community benefit societies, friendly societies, building societies and other mutual forms have different governing and tax rules.

Safe next step: Split the family by statute and activity before adding legal-form, attribution, reporting and obligation classifications.

coverage gap

Unincorporated associations not yet modelled

An association can lack separate general-law personality while tax and administration still assign duties to officers, trustees or the association name.

Safe next step: Add governing-law, Corporation Tax, trust-property and officer-duty sources with separate synthetic subjects.

coverage gap

Statutory bodies not yet modelled

Public corporations, authorities and office-holders derive identity and exemptions from their own enactments rather than one reusable company rule.

Safe next step: Model each statutory body's creating instrument, tax provision, public function and filing role separately.

coverage gap

Investment vehicles not yet modelled

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.

Safe next step: Add vehicle-specific legal, regulatory, tax-attribution, reporting and election sources before publishing classifications.

Source register

36 primary and official sources.

A source supports only the claims named in the corpus. Its limitations stay attached, and guidance is not silently promoted into legislation.

legislation ยท UK Parliament

Partnership Act 1890, section 1

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Legal personality differs within the UK and tax statutes can apply a different treatment.

legislation ยท UK Parliament

Partnership Act 1890, section 4

United Kingdom ยท retrieved 28 July 2026

Supports

  • A Scottish firm is a legal person distinct from its partners.

Limitations

  • Separate Scottish legal personality does not by itself decide the treatment under a particular tax.

legislation ยท UK Parliament

Companies Act 2006, section 16

United Kingdom ยท retrieved 28 July 2026

Supports

  • Registration forms a body corporate capable of exercising the functions of an incorporated company.

Limitations

  • Corporate existence does not settle residence, beneficial ownership, VAT grouping or foreign tax classification.

legislation ยท UK Parliament

Limited Liability Partnerships Act 2000, section 1

Great Britain at creation; later extended to Northern Ireland ยท retrieved 28 July 2026

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.

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.

legislation ยท Northern Ireland Assembly

Limited Liability Partnerships Act (Northern Ireland) 2002, section 1

Northern Ireland ยท retrieved 28 July 2026

Supports

  • Northern Ireland created its own LLP form as a body corporate with legal personality separate from its members.

Limitations

  • This is an origin source, not current standalone law: Companies Act 2006 section 1286 later provided that the Act ceased to have effect.

legislation ยท UK Parliament

Companies Act 2006, section 1286

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Formation date, commencement and transitional provisions still matter for a point-in-time conclusion.

official guidance ยท HM Revenue & Customs

PM120100: What is a partnership?

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • HMRC manuals explain HMRC's view and are not themselves legislation.

official guidance ยท HM Revenue & Customs

PM131450: LLP taxation

United Kingdom ยท retrieved 28 July 2026

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.

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.

official guidance ยท HM Revenue & Customs

PM136000: Taxing partnership profits

United Kingdom ยท retrieved 28 July 2026

Supports

  • Partnership business profits are computed at partnership level and attributed to partners.
  • The partnership can still carry PAYE and VAT responsibilities.

Limitations

  • Transparent and opaque are shorthand; charge-specific rules still control.

official guidance ยท HM Revenue & Customs

INTM180010: Foreign entity classification

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • A general HMRC view can vary after examining a specific foreign entity's constitution and facts.

official guidance ยท HM Revenue & Customs

INTM120040: Company residence incorporation rule

United Kingdom ยท retrieved 28 July 2026

Supports

  • Subject to stated exceptions, a UK-incorporated company is UK resident for corporation tax.

Limitations

  • Treaty rules and the full statutory exceptions must be checked.

official guidance ยท HM Revenue & Customs

INTM120180: Reviewing company residence

United Kingdom ยท retrieved 28 July 2026

Supports

  • Central management and control is a factual inquiry informed by the governing law and constitution.

Limitations

  • Meeting location alone is not conclusive.

official guidance ยท HM Revenue & Customs

RDRM20060: Domicile background and the 2025 change

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Historical periods and taxes outside the changed regime require their own rules.

official guidance ยท HM Revenue & Customs

TSEM1563: Bare trusts

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Whether a trust is bare depends on its terms and facts and can require legal advice.

official guidance ยท HM Revenue & Customs

TSEM10020: Trustees as a single person and trustee residence

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • The deemed-person rule is tax-specific and does not turn the trust arrangement into a general-law legal person.

official guidance ยท HM Revenue & Customs

TSEM4200: Settlor-interested settlements

United Kingdom ยท retrieved 28 July 2026

Supports

  • Some settlement income can be treated as the settlor's income.

Limitations

  • The detailed statutory conditions and exceptions control.

legislation ยท UK Parliament

Finance Act 2010, Part 1

United Kingdom ยท retrieved 28 July 2026

Supports

  • Tax law defines charity, charitable company and charitable trust for the taxes within its scope.

Limitations

  • Charity-law registration and tax recognition are related but not identical classifications.

official guidance ยท HM Revenue & Customs

Tax exemptions for charities

United Kingdom ยท retrieved 28 July 2026

Supports

  • Charitable-company and charitable-trust exemptions arise under different tax provisions.
  • Relief is conditional, including on application of income to charitable purposes.

Limitations

  • Charity status is not a blanket exemption from every tax or activity.

official guidance ยท HM Revenue & Customs

Group and divisional registration, VAT Notice 700/2

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Eligibility, establishment, control and anti-avoidance conditions must be checked.

official guidance ยท HM Revenue & Customs

VATREG08750: Registration of partnerships

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Scottish partnerships and changes in partner composition require separate treatment.

official guidance ยท HM Revenue & Customs

INTM162060: Branches, permanent establishments and residence certificates

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • The existence and profit attribution of a permanent establishment are separate technical questions.

model standard ยท OECD

OECD Model Tax Convention 2017

International ยท retrieved 28 July 2026

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.

Limitations

  • The applicable bilateral treaty and its current protocol control, not the model alone.

model standard ยท OECD

Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 final report

International ยท retrieved 28 July 2026

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.

Limitations

  • The actual treaty, multilateral-instrument position, domestic law, effective date and facts control.

model standard ยท OECD

Consolidated text of the Common Reporting Standard 2025

International ยท retrieved 28 July 2026

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.

Limitations

  • Domestic implementation and effective dates control reporting obligations.
  • The 2025 consolidation includes amendments whose first exchanges are expected later.

model standard ยท Financial Action Task Force

Guidance on Beneficial Ownership of Legal Persons

International ยท retrieved 28 July 2026

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.

Limitations

  • FATF standards require domestic implementation and do not decide a person's tax liability.

model standard ยท Financial Action Task Force

Guidance on Beneficial Ownership and Transparency of Legal Arrangements

International ยท retrieved 28 July 2026

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.

Limitations

  • The governing law and domestic implementation remain decisive.

regulation or directive ยท European Union

Council Directive 2006/112/EC, Articles 9 and 10

European Union ยท retrieved 28 July 2026

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.

Limitations

  • Member-state implementation and post-exit UK VAT law must be checked for the relevant period.

regulation or directive ยท European Union

Council Implementing Regulation 282/2011, Article 11

European Union ยท retrieved 28 July 2026

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.

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.

official guidance ยท GOV.UK

Employment status: self-employed and contractor

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • The page is general guidance and does not determine a real engagement.

official guidance ยท GOV.UK

PAYE and payroll for employers

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Registration thresholds, worker status, special cases and the rules for the period still need separate checks.

official guidance ยท HM Revenue & Customs

VAT guide, Notice 700

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • General guidance does not replace the VAT Act, detailed manuals or transaction-specific rules.

official guidance ยท HM Revenue & Customs

VATPOSS04500: fixed establishment

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • The conclusion is provision-specific and fact-specific, and relevant case law and current legislation must also be checked.

official guidance ยท Internal Revenue Service

Classification of taxpayers for US tax purposes

United States ยท retrieved 28 July 2026

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.

Limitations

  • Disregarded treatment has charge-specific exceptions and does not determine UK treatment.

regulation or directive ยท US Department of the Treasury

Treasury Decision 8697

United States ยท retrieved 28 July 2026

Supports

  • The check-the-box entity-classification regulations generally became applicable in 1997.

Limitations

  • Later amendments and the current Code and regulations must be checked.

official guidance ยท HM Revenue & Customs

Help with sharing group structure information

United Kingdom ยท retrieved 28 July 2026

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.

Limitations

  • Diagram notation communicates claims; it does not prove them.

official guidance ยท HM Revenue & Customs

How to set up as a sole trader

United Kingdom ยท retrieved 28 July 2026

Supports

  • A sole trader and the business are not separate legal persons.
  • A trading name does not create a separate person.

Limitations

  • Tax obligations still depend on activities, income, registrations and period.

Public, read-only API

Carry the dimensions and boundaries into software.

The API publishes this versioned corpus, its graph, schema and synthetic examples without an account. It accepts no taxpayer facts and produces no filing position.

Framework index Full identity graph Synthetic examples Source register JSON Schema OpenAPI slice

Corpus version 2026-07-28.2 ยท reviewed 28 July 2026 ยท CC BY-SA 4.0

Licence 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.