David Nickson Tax Partner KPMG LLP discusses HMRC's announcement on 21 January regarding asset contributions to partnerships and capital gains
HMRC's announcement on 21 January regarding asset contributions to partnerships and capital gains1 was a surprise in more ways than one. Firstly with tax professionals currently having so many opportunities to consult on other measures this came like a bolt out of the blue. But more importantly what was billed as a 'clarification' has produced mainly confusion.
Background
The taxation of capital gains arising in respect of partnership assets is dealt with by TCGA 1992 s 59. Section 59 merely provides that the partnership itself is to be ignored for capital...
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David Nickson Tax Partner KPMG LLP discusses HMRC's announcement on 21 January regarding asset contributions to partnerships and capital gains
HMRC's announcement on 21 January regarding asset contributions to partnerships and capital gains1 was a surprise in more ways than one. Firstly with tax professionals currently having so many opportunities to consult on other measures this came like a bolt out of the blue. But more importantly what was billed as a 'clarification' has produced mainly confusion.
Background
The taxation of capital gains arising in respect of partnership assets is dealt with by TCGA 1992 s 59. Section 59 merely provides that the partnership itself is to be ignored for capital...
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If you do not subscribe but are a registered user, please enter your details in the following boxes: