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Mixing it up

06 August 2013 / Dean Wootten
Issue: 4414 / Categories: Comment & Analysis , Business

Mixed partnerships of individuals and companies may not be so popular in future


  • The use of a corporate partner has many tax advantages.
  • FA 2013 Sch 30 introduces anti-avoidance rules on loans by close companies.
  • Loans to employee benefit trusts and loans back from companies will now be subject to a s 455 charge.
  • HMRC plans to remove the presumption of self employment for some LLP members.
  • Inappropriate allocations of partnership profits may be targeted in FA 2014.

Introducing a corporate partner into a partnership has been popular for many years and has significant tax advantages for profitable partnerships. Invariably the partners will also be the owners of the company and as such the profit earned by the business will essentially stay in the same ownership – albeit with a significant element of the profit routed through...

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