Market leading insight for tax experts
View online issue

Partnerships and the BlueCrest appeals: doubling down

Speed read
The Upper Tribunal has found that corporation tax rules taxing partners on their share of partnership profits are not subject to the general rule that a company is not taxable on profits that accrue to it as a fiduciary. As a result, the taxpayer was taxable on its share of partnership profits even though it had contributed that share to another partnership. Recent statutory changes can mitigate this outcome but do not cover all eventualities. In addition, these twin appeals confirm that non-resident corporate partners cannot get tax relief for borrowings taken out to acquire a partnership interest; and that the miscellaneous income charge has broad application in the context of deferred remuneration arrangements for individual partners.

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
300 x 250 (MPU)
Top