By George Bull
Draft legislation dealing with ‘disguised salary’ of LLP members partnerships with individual and company members and further anti-avoidance measures has been announced.
While HMRC has clearly listened closely to consultation responses and amended some of the proposals to reflect this we fear that innocent arrangements will be caught. Firms should take time now to understand how the changes will affect them and decide what – if any – action is required. The legislation will generally take effect from 6 April 2014 with anti-avoidance measures coming into effect from 5 December 2013 to catch any tax-motivated profit allocation structures.
Disguised salary: Under the draft legislation a member of a limited liability partnership (LLP) will be treated as an employee for tax purposes if all the following conditions are met:
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By George Bull
Draft legislation dealing with ‘disguised salary’ of LLP members partnerships with individual and company members and further anti-avoidance measures has been announced.
While HMRC has clearly listened closely to consultation responses and amended some of the proposals to reflect this we fear that innocent arrangements will be caught. Firms should take time now to understand how the changes will affect them and decide what – if any – action is required. The legislation will generally take effect from 6 April 2014 with anti-avoidance measures coming into effect from 5 December 2013 to catch any tax-motivated profit allocation structures.
Disguised salary: Under the draft legislation a member of a limited liability partnership (LLP) will be treated as an employee for tax purposes if all the following conditions are met:
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: