HM Revenue & Customs (HMRC) has rewritten its guidance on capital gains tax relating to members of partnerships.

The new rules, which follow a rise in the number of partnerships in recent years, highlights several issues, especially where partners introduce assets that they already own and where corporate members are involved.

George Bull, head of tax at accountancy firm Baker Tilley, said the new guidance would also affect companies that are members.

“If two group companies form a partnership, their disposals to the partnership will not be taxable because of the exemption for intra-group transfers provided by section 171 of the Taxation of Chargeable Gains Act 1992,” he said.

“But if another member joins the partnership and the interests in the asset change, there can be a chargeable disposal.”