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FA 2014: Mixed membership partnerships

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Finance Act 2014 has inserted new rules into ITTOIA 2005, ITA 2007 and CTA 2009 that have significantly changed the way in which partnerships with a mix of individual and non-individual members are taxed. The rules are effectively anti-avoidance rules and have been introduced to counteract the insertion of non-individual members into partnerships to defer or reduce the tax liabilities of individual members. The introduction of the rules reflects a context of general misgivings about the use of corporate bodies in partnerships, which have been expressed in the Transparency and Trust discussions conducted by the Department of Business Innovation and Skills.

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