Taxpayer liable to income tax on sums payable by overseas entities
In S Smart v HMRC [2025] UKFTT 701 (TC) (12 June) the FTT dismissed the taxpayer’s appeal against assessments and a closure notice charging income tax on distributions paid by entities forming part of a multinational group in one part of which the taxpayer was a partner in an LLP. He was the person ‘receiving or entitled’.
The taxpayer was a partner of an LLP which was part of a Brazilian financial group (BTG) whose activities included investment banking advisory services and wealth and asset management. On becoming a partner the taxpayer was required to acquire shares in several other group entities his acquisitions being funded by loans from other related entities. Several of the entities paid ‘interest on net equity’ (JCP) in respect of the shares held by the appellant. It was common...
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Taxpayer liable to income tax on sums payable by overseas entities
In S Smart v HMRC [2025] UKFTT 701 (TC) (12 June) the FTT dismissed the taxpayer’s appeal against assessments and a closure notice charging income tax on distributions paid by entities forming part of a multinational group in one part of which the taxpayer was a partner in an LLP. He was the person ‘receiving or entitled’.
The taxpayer was a partner of an LLP which was part of a Brazilian financial group (BTG) whose activities included investment banking advisory services and wealth and asset management. On becoming a partner the taxpayer was required to acquire shares in several other group entities his acquisitions being funded by loans from other related entities. Several of the entities paid ‘interest on net equity’ (JCP) in respect of the shares held by the appellant. It was common...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
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