In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
Limited Liability Partnerships were introduced as a new legal entity in 2000 to combine the organisational flexibility and tax status of a partnership with the limited liability of a limited company. Under legal principles a LLP is a body corporate a separate legal entity but for tax purposes a LLP is treated as a partnership under ITTOIA 2005 s 863 (CTA 2009 s 1273). Where carrying on a trade profession or other business with a view to profit all the activities of the LLP are treated as being carried on in partnership by its members (and not the...
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In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
Limited Liability Partnerships were introduced as a new legal entity in 2000 to combine the organisational flexibility and tax status of a partnership with the limited liability of a limited company. Under legal principles a LLP is a body corporate a separate legal entity but for tax purposes a LLP is treated as a partnership under ITTOIA 2005 s 863 (CTA 2009 s 1273). Where carrying on a trade profession or other business with a view to profit all the activities of the LLP are treated as being carried on in partnership by its members (and not the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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