My business partners and I are considering how best to structure a joint investment venture. Save for one of us who is a non-UK resident of non-UK origin we are all UK tax residents and want to contribute various assets to the venture without crystallising their substantial latent gains. We are therefore considering a limited partnership due to its transparent tax status. Guernsey is a jurisdiction we know well. Is there anything we need to be aware of from a UK tax perspective before using a Guernsey limited partnership?
A Limited partnerships (LPs) have long been employed for co-investment purposes and are frequently used by parties acting together in the common pursuit of profit including in the context of making managing and holding investments. LPs’ flexibility tax transparency and their provision of limited liability are some headline attractions for co-investors organising their activities.
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