This year’s Finance Act has made significant changes to the taxation of partnerships with a mix of individual and non-individual members. Howard Murray and Josh Lom (Herbert Smith Freehills) provide your guide to the new rules
The new rules on mixed membership partnerships are broad in scope and may apply to a number of relatively commonplace commercial scenarios. There is also potential exposure to double taxation if diverted profits are not repaid to relevant individuals in the right way. As such it is important that practitioners and business people are aware of the complexities that can arise out of aspects of the new legislation.
(All statutory references in this article are to ITTOIA 2005 unless otherwise indicated.)
