UK resident individual members of LLCs and other reverse hybrids
Read the full outcome
Detail of outcome
The government has published a summary of responses to the consultation ‘UK resident individual members of LLCs and other reverse hybrids’, which explored how to resolve high effective rates of taxation experienced by UK resident individuals investing in US Limited Liability Companies (LLCs) and other ‘reverse hybrids’.
This document provides a summary of the responses received and sets out the government’s view and next steps.
The government is committed to the UK remaining a leading destination for global talent and responding where issues emerge, which is why the government intends to resolve this issue through the creation of a mechanism to provide double taxation relief.
Original consultation
Consultation description
This consultation details the current tax position for UK resident individuals who are members of reverse hybrids such as US LLCs and identifies where unintentionally high effective tax rates may arise for these individuals, due to entity classification mismatches between the UK and other jurisdictions that results in double taxation. It sets out proposed solutions and invites feedback from stakeholders.