Mixed partnerships: new rules from HMRC
By Niall Murphy
HMRC published draft legislation on 10 December 2013 to deal with perceived tax avoidance by partnerships.
This article explores profit and loss allocations by partnerships, the special rules for alternative investment fund managers and the disposal of assets through partnerships that lead to a tax advantage. Typically, these new rules are aimed at mixed partnerships, i.e. partnerships that consist of both individuals and corporates.
The draft legislation indicates that the new measures will apply to partnership accounting years starting on or after 6 April 2014, with accounting periods that straddle that date being divided so that a new period of account is assumed to commence on 6 April 2014…
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