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Tax and the City briefing for March 2014

Helen Lethaby reviews recent developments affecting the City

Limited liability partnerships: salaried members

It is now less than a month until the start of the new tax year and many LLPs will be finalising arrangements designed to ensure that members currently taxed as partners do not get recharacterised as employees under the new rules on salaried members (effective from 6 April 2014). ‘Salaried member’ status will attach to an individual who meets each of the following three conditions: 80% or more of his remuneration is ‘disguised salary’ (a fixed amount or a variable bonus which is not dependent on overall firm performance); he does not have ‘significant influence’ over the firm’s affairs; and his contributed capital broadly as measured at the start of a tax year is less than 25% of his...

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