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STOP PRESS: The remittance basis is abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

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

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

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

The taxation of UK resident partners in a partnership controlled overseas is outside