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HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
Updated
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Business Income Manual: Computing the amount to assess: Mixed Membership Partnerships: Excess profit allocation: contents

The guidance on the excess profit allocation rules contains the following sections:

BIM82720 Who is a non-individual partner
   
BIM82725 When do the excess profit allocation rules apply?
BIM82730 Condition X – Deferred remuneration
BIM82740 Condition Y – where the individual has the power to enjoy
BIM82745 Condition Y - The Appropriate notional profit
BIM82770 Condition Y - Definition of the “power to enjoy”
BIM82790 Condition Y - Is the profit share influenced by the “power to enjoy”
BIM82800 The relevant tax amount
BIM82805 Calculating the amount to be reallocated for individuals
BIM82810 Calculating the amount to be reallocated – non-individuals
BIM82815 Payments by the non-individual out of the reallocated profit share.
BIM82825 Interaction with the AIFM deferral arrangements
BIM82830 Anti-avoidance rules
BIM82850 Particular issues
BIM82855 Particular issues – businesses transferred to the partnership
BIM82870 Particular issues – takeover of the LLP
BIM82880 Particular issues – Private equity investment
BIM82890 Particular issues – Share issues
BIM82900 Particular issues –pseudo share schemes
BIM82910 Particular issues – International structures
BIM82945 Commencement