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A UK Limited liability partnership (LLP) is a body corporate for Company law purposes, but is generally taxed as though it were a Partnership (ie it is tax transparent). This means that where an LLP carries on a trade, profession or business with a view to a profit, its profits and gains will normally be taxed in the hands of its members, rather than being assessed on the LLP itself. Tax transparency also means that the members will be taxed on the LLP's profits and gains at the time they arise, whether or not they have been distributed to the members. In some circumstances, tax transparency may not apply or may be lost, see When is an LLP not tax transparent? below.

Members of LLPs are normally taxed on their share of the LLP's profits following the rules applying to partners in a general partnership, for which, see Practice Note: Taxation of general partnerships. There are specific rules which only apply to LLPs and these specific rules are considered in this Practice Note.

The special capital gains rules