Mixed partnership anti-avoidance rules

 

I act for an LLP which has always had only corporate members. In light of the mixed partnership rules is it safe to introduce a new corporate partner into this structure?

 

 

ITTOIA 2005 s 850C deals with mixed partnerships that is any partnership (including an LLP) in which an individual is a member together with a company where it is reasonable to suppose that the individual’s ‘deferred profit’ is included in the company’s profit share or that the individual has ‘power to enjoy’ the income...