Dominic Foulkes and Jonathan Cooklin (Davis Polk) share their approach to understanding some of the tax issues.
Readers of this journal will frequently encounter partnerships when looking at business organisations and transactions. They may occur to facilitate commercial objectives such as tax neutral fund vehicles commercial co-ownership and carry/incentive vehicles for managers; or for the purposes of non-UK tax planning as well as for any UK tax attributes which the introduction of a partnership might confer. It is well known that partnerships are ‘transparent’ for the purposes of UK corporation tax on income and gains (see HMRC’s Partnership Manual at PM10700 for example); it is equally obvious that UK tax legislation does not deal with partnerships very comprehensively or satisfactorily.
In this article – which for the most part focuses on the taxation of gains rather than income – we suggest that a more helpful starting...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Dominic Foulkes and Jonathan Cooklin (Davis Polk) share their approach to understanding some of the tax issues.
Readers of this journal will frequently encounter partnerships when looking at business organisations and transactions. They may occur to facilitate commercial objectives such as tax neutral fund vehicles commercial co-ownership and carry/incentive vehicles for managers; or for the purposes of non-UK tax planning as well as for any UK tax attributes which the introduction of a partnership might confer. It is well known that partnerships are ‘transparent’ for the purposes of UK corporation tax on income and gains (see HMRC’s Partnership Manual at PM10700 for example); it is equally obvious that UK tax legislation does not deal with partnerships very comprehensively or satisfactorily.
In this article – which for the most part focuses on the taxation of gains rather than income – we suggest that a more helpful starting...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
