My client is a partner in a UK limited partnership which holds shares in a foreign trading company. With the increase in UK regulation the limited partners would like to transfer the partnership assets into a Guernsey LLP and end their UK operations entirely. The proposal is that the limited partnership will be dissolved. At the same time the limited partners will direct that the shares in the trading company will be transferred into the LLP in return for membership rights. As my client is UK resident and domiciled what UK tax risks should she consider?
Whilst the proposed structure may provide few UK tax challenges for non-resident limited partners there are a wide range of tax considerations for a UK resident limited partner.
Firstly there is the risk that a tax charge may arise on the...
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