H4. Contribution of asset/business

- Ownership of partnership assets

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- "[145] It is clear to us from the cases cited that the partners of a partnership do not own the assets which comprise the partnership property, they have instead a beneficial interest in the realised value of that property." (Armour Veterinary Group)

- Same conclusion if Scottish Partnership (§193).

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Legislation: 

Cases: 

Armour Veterinary Group Ltd v. HMRC [2024] UKFTT 539 (TC), Judge Tilakapala

HMRC manuals: 

Commentary: 

See also:

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