PARTNERSHIPS

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.

Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.

Adam Kay

Susan Dennis

The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.

Andrew Howard

Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.

Rupert Lee

New legislation brings certain partnerships within the scope of Jersey’s economic substance regime. Rupert Lee (Deloitte Jersey) reports.

Daniel Johnson

Chris Chatting

Daniel Johnson and Chris Chatting (Deloitte) consider why this issue has been raised now and what the future changes might be.

Andrew Howard

Even by the standards of tax cases, the recent case of BlueCrest Capital Management Cayman Ltd & others v HMRC is a difficult read. However, it is worth persevering with, because HMRC has taken the opportunity to test out a number of theories on partnership taxation, with some fairly alarming results for taxpayers.

Zoe Andrews

Time for a wholesale review?

Jitendra Patel

Jitendra Patel (BDO) examines the rules six years since their introduction and in light of the first reported case on their application.

David Whiscombe

The tax affairs (and, more specifically, the tax returns) of partnerships and partners continue to create more than their fair share of controversy and procedural dispute. The latest is the First-tier Tribunal decision in Grinyer [2020] UKFTT 64 (TC).

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