PM274200 - General transparency principal
In line with other direct taxes, partnerships are treated as 鈥榯ransparent鈥� for the purposes of IHT. See PM136000 for an explanation of the 鈥榯ax transparency principle鈥�.
As Limited Liability Partnerships (LLPs) are bodies corporate in law, specific provision is made to treat these in the same manner as other partnerships (IHTA 1984/S267A and LLPA 2000/S11).
Where an overseas partnership is involved, you will need to consider whether the particular entity concerned would be regarded as a partnership under UK law.