PARTNERSHIPS

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.

David Whiscombe

Boulting cannot be regarded as a satisfactory case, except as to its outcome in favour of the taxpayer, writes David Whiscombe.

Promoters of film finance partnerships authorised to receive notice of enquiries into returns

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

Redress payment taxable as post-cessation receipt

No entitlement to deductions for amortisation of purchased goodwill

No SDLT due on distributions of partnership and its properties following purchase of JPUT holding structure.

High Court dismisses claim for declaratory relief in relation to failed film partnership scheme

Michael Ridsdale

Gemma Williams

Michael Ridsdale and Gemma Williams (Wedlake Bell) illustrate how to ensure certainty of tax treatment on the structuring of a residential property development.

David Haworth

David Haughey

David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.

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