Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Investec: partnership profits brought into tax computation of partners’ financial dealing trades
HMRC v Investec Asset Finance PLC and another [2018] UKUT 413 (TCC) is a good reminder that whilst partnerships have existed as a creature of English law for a long time and are very widely used there are very few provisions in the UK tax code dealing expressly with them and they have a tendency to throw up some difficult questions. Often this occurs in areas where the rule that tax follows the accounts (which respect the partnership as a separate entity) bumps up against tax transparency (provided for by a relatively short-form statutory section).
To cut a (very) long story (very) short in this case two taxpayer companies with financial trades (IAF and IAB) bought some interests in leasing partnerships....
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Investec: partnership profits brought into tax computation of partners’ financial dealing trades
HMRC v Investec Asset Finance PLC and another [2018] UKUT 413 (TCC) is a good reminder that whilst partnerships have existed as a creature of English law for a long time and are very widely used there are very few provisions in the UK tax code dealing expressly with them and they have a tendency to throw up some difficult questions. Often this occurs in areas where the rule that tax follows the accounts (which respect the partnership as a separate entity) bumps up against tax transparency (provided for by a relatively short-form statutory section).
To cut a (very) long story (very) short in this case two taxpayer companies with financial trades (IAF and IAB) bought some interests in leasing partnerships....
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:
