Corporation tax rate complexities for corporate LLP members

Companies must identify their augmented profits and associated companies to ensure they apply the correct rate of corporation tax. This can be particularly challenging when it comes to corporate members of LLPs. Whether dividend income received by an LLP needs to be included in the augmented profits of corporate members is not always clear and will depend on the exact facts and circumstances. While two corporate members will not be associated with each other just because they have interests in the same LLP, careful consideration of the individual shareholders’ interests and their connections will be needed in all cases.