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Partnership Taxation

Author: David Whiscombe

Publication Date: July 2020

Publisher: Bloomsbury Professional

Law As Stated At: 1 June 2020

Partnership Taxation

Partnership Taxation

A comprehensive examination of the law and best practice relating to the taxation of partnerships in the UK, including LLPs, Limited Partnerships and Private Fund Limited Partnerships.

It gives expert guidance on the planning points and pitfalls to be aware of when considering the taxation of partnerships and compares them with alternative structures. It includes many worked examples and legislative references throughout. The appendices include a useful table of the penalties that may apply to partnerships, and an illustration of the main clauses in a partnership agreement that have a taxation effect.

Brought up to date with Finance Act 2019, it includes full analysis of key developments, including:

  • how the significant changes to Entrepreneurs’ Relief will affect companies in partnership
  • how the new rules on CGT liability of non-residents applies to foreign partnerships and to non-resident partners in UK partnerships
  • how control of a company by an LLP is treated as ‘control by a body corporate’ for EMI, EIS and SEIS purposes
  • implications of Brexit.

This edition will also interpret key new case law, including:

  • R v Locke [2018] EWHC 1967, on interest relief paid on loans used to provide money to a partnership
  • Leverington v HMRC [2018] UKFTT 540 (TC), on the validity of a partnership notice to file
  • Altus Group v Baker Tilly [2015] EWHC 411 (Ch), on deductibility of payments from one LLP to another
  • Clyde & Co LLP v Bates van Winkelhof [2014] UKSC 32, on LLP members as ‘limb (b)’ workers
  • Kenroy Coke v HMRC [2018] UKFTT 602 (TC), on whether a partnership existed.

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