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Examining the proposals on partnerships and LLPs

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In Budget 2013, the government announced that it would review the use of partnerships in tax planning. It has now proposed legislative changes from 6 April 2014 to block the manipulation of profit and loss allocations to secure a tax advantage. It has also now published a formal consultation on anti-avoidance legislation for LLPs to be effective from 6 April 2014. The proposals will affect many LLPs which have a wide range of partners with differing financial entitlements – particularly those with ‘fixed share’ partners or ‘junior’ partner ranks. This will affect many firms in the asset management, hedge fund and private equity sectors.

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