A limited company operates a children’s nursery. It loaned money to a limited liability partnership to start a second nursery. The LLP consists of the limited company and its controlling director/shareholder
The LLP has raised half the finance itself but due to difficulties in obtaining bank finance it has also been supported by a loan from P Limited of £400 000 in October 2102; the company also introduced the branding and expertise of running a nursery.
Given the proposed new rules in connection with LLPs and a charge under CTA 2010 s 455 do readers have any suggestions that would...
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