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Partnership tax changes: three months left to prepare

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 an individual performs services for the LLP and...

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