In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
Limited Liability Partnerships were introduced as a new legal entity in 2000 to combine the organisational flexibility and tax status of a partnership with the limited liability of a limited company. Under legal principles a LLP is a body corporate a separate legal entity but for tax purposes a LLP is treated as a partnership under ITTOIA 2005 s 863 (CTA 2009 s 1273). Where carrying on a trade profession or other business with a view to profit all the activities of the LLP are treated as being carried on in partnership by its members (and not the...
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In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
Limited Liability Partnerships were introduced as a new legal entity in 2000 to combine the organisational flexibility and tax status of a partnership with the limited liability of a limited company. Under legal principles a LLP is a body corporate a separate legal entity but for tax purposes a LLP is treated as a partnership under ITTOIA 2005 s 863 (CTA 2009 s 1273). Where carrying on a trade profession or other business with a view to profit all the activities of the LLP are treated as being carried on in partnership by its members (and not the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
