CRA indicates that a UK LLP is a corporation in light [inter alia?] of its separate legal personality

Under the UK’s Limited Liability Partnerships Act 2000, a limited liability partnership (“UK LLP”) is treated in the UK as a separate legal entity, but the profits of its business are taxed as if the business were carried on by partners in partnership, rather than by a body corporate

CRA orally indicated that it would consider the UK LLP to be a corporation under its two-step approach, in light of the LLP’s separate legal personality.

There presumably is more to the CRA’s position than this – otherwise it would contradict its position that an ordinary Delaware LP (as contrasted to an LLP or LLLP) is a partnership for ITA purposes notwithstanding that such “a limited partnership is a separate legal entity:” 14 August 2008 External T.I. 2004-0104691E5. Also note that Scottish partnerships have been found to be partnerships under a two-step approach despite their separate legal personality (see Anson, [2013] EWCA Civ 63, at para. 64, rev'd on other grounds).

Neal Armstrong. Summary of 27 October 2020 CTF Roundtable, Q.9 under s. 248(1) – corporation.