Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s round-up that includes Spring Finance Bill measures affecting financial services.
Muller: whether corporate members are ‘related parties’ of an LLP
The question before the First-tier Tribunal (FTT) in Muller UK & Ireland and others v HMRC [2023] UKFTT 221 (TC) was whether the corporate members of an LLP were ‘related parties’ of the LLP for the purposes of CTA 2009 s 882(1). The definition of ‘related party’ in the legislation was amended by FA 2016 s 52 with effect to accounting periods commencing on or after 25 November 2015 but the decision in this case is of interest for its consideration of how both before and after the legislative change the intangible fixed assets (IFA) rules apply to a partnership.
The taxpayers three corporate members of the LLP had transferred their respective trades to...
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Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s round-up that includes Spring Finance Bill measures affecting financial services.
Muller: whether corporate members are ‘related parties’ of an LLP
The question before the First-tier Tribunal (FTT) in Muller UK & Ireland and others v HMRC [2023] UKFTT 221 (TC) was whether the corporate members of an LLP were ‘related parties’ of the LLP for the purposes of CTA 2009 s 882(1). The definition of ‘related party’ in the legislation was amended by FA 2016 s 52 with effect to accounting periods commencing on or after 25 November 2015 but the decision in this case is of interest for its consideration of how both before and after the legislative change the intangible fixed assets (IFA) rules apply to a partnership.
The taxpayers three corporate members of the LLP had transferred their respective trades to...
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:
