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A real headache
Key points
- The Court of Appeal considered two issues: the composition of the partners in a partnership; and the deductibility of interest.
- Consider the case of Major v Brodie [1998] STC 491 with regard to what constitutes a partnership.
- Was Cayman Ltd acting as fiduciary or representative of the corporate limited partner when the right to super profits accrued?
- The Court of Appeal considered that taxing Cayman Ltd on the profit allocation did not give rise to double taxation.
- When dealing with tiered partnerships give careful thought to the nature of the partnership used and to frame and comply scrupulously with the requirements for partnership admission.
What if a partner of limited partnership A with no legal personality becomes a partner of limited partnership B in its capacity as the general partner of partnership A: are the limited partners in partnership A partners of partnership B?
If not...
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