A review of two aspects of the tax rules on partnerships
Download the full outcome
Detail of outcome
The government has confirmed it will take forward the partnerships proposals which will prevent avoidance and remove the tax advantages set out in the consultation document. This document summarises the response to the consultation and sets out the changes to the detailed policy design the government has made as a result of the feedback it received.
Legislation relating to mixed membership partnerships was published on 5 December 2013 and had immediate effect. The complete package of draft legislation was published on 10 December 2013 for consultation.
Original consultation
Consultation description
At Budget 2013, the Chancellor announced that the government would consult on changes to two aspects of the tax rules on partnerships in order to prevent tax loss arising from:
- disguising employment relationships through limited liability partnerships; and
- certain arrangements involving allocation of profits and losses among partnership members
Those changes will take effect from 6 April 2014.
The government would welcome views on the detailed design of the changes and on how to ensure that any impacts outside the specified targeted areas can be reduced without giving rise to uncertainty and avoidance.
Further information
National Insurance Bill 2013
- National Insurance Contributions Tax Impact and Information Note
- More information on the National Insurance Bill 2013
- Parliamentary information on the National Insurance Bill 2013
Draft tax legislation and guidance
- Salaried Member Rules: Legislation day technical note and guidance
- Mixed Membership Partnership, Alternative Investment Fund Manager and Asset Disposal Rules: Legislation day technical note and guidance
- Finance Bill 2014: legislation, explanatory notes and guidance
- Draft Finance Bill 2014 Legislation, Tax Impact & Information Notes and Technical Note - 10 December 2013 (see “Partnerships” document)
- Salaried members Rules: revised technical note and guidance
- Salaried members: revised draft Finance Bill 2014 legislation, explanatory note and Tax Information and Impact Note
Alternative Investment Fund Managers: forms and guidance
Finance Bill 2014
Documents
Last updated 28 March 2014 + show all updates
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Legislation day technical notes and guidance about Salaried Member Rules and Mixed Membership Partnership, AIFMs and Asset Disposal Rules have been added to this consultation.
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added link to 'Finance Bill 2014: legislation, explanatory notes and guidance'
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Alternative Investment Fund Managers mechanism: election form and guidance has been added to this consultation.
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A link to the document collection which includes Salaried members: revised draft Finance Bill 2014 legislation, explanatory note and tax information and impact note has been added to this page.
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Updated to include a link to "Salaried Members Rules: revised technical note and guidance"
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Added a link to the finance bill 2014.
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Added a Further Information link under Draft tax legislation and guidance.
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Updated to include summary of responses and changes to the detailed policy design the government has made as a result of the feedback it received.
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Updated to include slides from open meeting
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First published.