LLPS

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.

QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...

Discretionary deferred profits via a corporate LLP were taxable as miscellaneous income

UT confirms broad meaning of ‘business’

Upper Tribunal rules on payments under LLP ‘capital interests’ and the mixed member partnership rules

Licence of client list was an intangible fixed asset for CT purposes

While 2024 has not exactly been plain sailing for SMEs, the tax related developments have not been as radical or fundamental as might have been feared, writes Andrew Constable (Mercer & Hole).

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.