MIXED-PARTNERSHIPS

Emily Au

HMRC’s approach and recent tribunal decisions on mixed member partnership taxation have led to some uncertainty for individual and corporate partners. Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan) assess the current state of play and what can be done to minimise risks.

Natasha Kaye

Reshma David

Natasha Kaye and Reshma David (Cooley) examine the scope of the close company indirect loan to participator rule in CTA 2010 s 459.

Jitendra Patel

Jitendra Patel (BDO) examines the rules six years since their introduction and in light of the first reported case on their application.

Howard Murray

Josh Lom

This year’s Finance Act has made significant changes to the taxation of partnerships with a mix of individual and non-individual members. Howard Murray and Josh Lom (Herbert Smith Freehills) provide your guide to the new rules

James McCredie

Draft legislation is to be included in Finance Bill 2014 to counter tax avoidance through the use of a partnership, but with more people being affected than previously thought, there is more thinking to be done, says James McCredie.