Taxation of Salaried Members: An Update for Asset Managers

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Background -

Last summer, HM Revenue & Customs (HMRC) published proposals for major changes to the UK's rules on the taxation of partnerships. The primary aim of the proposals was to counter arrangements which HMRC regarded as tax avoidance—in particular:

1.disguised employment – the appointment of an individual as a member of a UK Limited Liability Partnership (LLP) who could more appropriately be regarded as an employee of the LLP (Salaried Member Rules); and

2.mixed member partnerships – the use of tax-motivated profit and loss allocation schemes by partnerships seeking to utilise the different tax attributes of partners (for example, corporate and individual members) (Mixed Member Rules).

Please see full advisory below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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