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The only activity of a limited liability partnership is as a property investment business. Tax losses are being carried forward with some reduction by subsequent profits. One of the partners now has personal property income, but the LLP losses cannot be set against it
My client is a limited liability partnership (LLP) with three partners who have equal shares. Its only activity is as a property investment business. Tax losses were incurred in past years which were carried forward.
However these losses have subsequently been reduced by more recent profits. Until recently none of the partners has been in receipt of other property income outside the LLP.
One of the parties now receives property income in their own right. The question is whether that partner can use their one-third share of the partnership losses brought forward to be set off against their other property income or can they only be used against their share of the future LLP profits?
Furthermore the partnership is about to purchase property on which capital allowances can be claimed. Can the allowances be claimed by some partners and not by others or must the claim...
