HMRC: partnership consultation — two avoidance issues

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On 20 May HMRC released a consultation regarding the taxation status of some LLP members and the manipulation of profits and losses by partnerships.

The taxation of partnerships generally has been under scrutiny for a while, with the suggestion that some have been abusing the structures to achieve advantageous tax results, particularly in relation to NICs, income tax and capital gains.

The two aspects being consulted on now deal with aggressive schemes that address two unrelated issues where HMRC believes NICs and income tax are being avoided…

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