Mixed partnership anti-avoidance rules

Anthony Newgrosh

Anthony Newgrosh (BKL) considers the introduction of a new corporate partner into an LLP under mixed partnership rules.

Question

I act for an LLP which has always had only corporate members. In light of the mixed partnership rules is it safe to introduce a new corporate partner into this structure?

Answer

ITTOIA 2005 s 850C deals

with mixed partnerships that is any partnership (including an LLP) in which an individual is a member together with a company where it is reasonable to suppose that the individual’s ‘deferred profit’ is included in the company’s profit share or that the individual has ‘power to enjoy’ the income of the company from the partnership and hence has an...

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