The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
In the Autumn Budget the government announced that it would be making changes to the tax rules relating to the liquidation of Limited Liability Partnerships (LLPs) with effect from 30 October 2024. In circumstances where a member has contributed assets to an LLP and the LLP is subsequently liquidated the new legislation introduces a retrospective tax charge at the time of the original contribution by that member.
This is a very specific piece of legislation but it forms part of the Government’s stated aim to introduce policies to close the tax gap. The particular objective is to prevent the use of a tax mitigation scheme which involves transferring assets standing at a gain to an LLP and subsequently liquidating the LLP with the...
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The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
In the Autumn Budget the government announced that it would be making changes to the tax rules relating to the liquidation of Limited Liability Partnerships (LLPs) with effect from 30 October 2024. In circumstances where a member has contributed assets to an LLP and the LLP is subsequently liquidated the new legislation introduces a retrospective tax charge at the time of the original contribution by that member.
This is a very specific piece of legislation but it forms part of the Government’s stated aim to introduce policies to close the tax gap. The particular objective is to prevent the use of a tax mitigation scheme which involves transferring assets standing at a gain to an LLP and subsequently liquidating the LLP with the...
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