Partnership Taxation
Author: David Whiscombe
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.
This update has been revised and updated to take account of the various developments in statute and case law, which includes:
Chapter 1 – Hoyle & others [2024] UKFTT 1060 (TC) re disposal of partnership interests.
Chapter 2 – Expansion and re-writing of material on treatment of partnerships under the CT intangible fixed asset regime.
Chapter 8 – Minor updating.
Chapter 12 – Armour Veterinary Group Ltd v HMRC [2024] UKFTT 00539 (TC) on the nature of a partner’s interest in partnership property.
Chapter 13 – Budget changes to BADR and investors’ relief and associated anti-forestalling provisions.
Chapter 16 – relocation of text to Chapter 2.
Chapter 19 – GCH Corporation & others v HMRC [2024] UKFTT 922 (TC) on exploitation of CGT rebasing on liquidation, and proposed legislation to counter it TCGA 1992 s59AA.
- Bluecrest Capital Management (UK) LLP [2025] EWCA Civ 23 on LLP salaried members
- HMRC withdrawal of previous interpretation of application of anti-avoidance rule to Condition C of salaried member rules.
Chapter 20 – Signposting prospective replacement of domicile with long-term residence as a factor relevant to tax treatment.