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HMRC internal manual

Business Income Manual

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HM Revenue & Customs
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Business Income Manual: Computing the amount to assess: Mixed Membership Partnerships: Excess profit allocation: Particular Issues

The following sections look at the application of the excess profit allocation rules to specific issues.

Guidance on the position when an existing business carried on by someone else is transferred to an LLP can be found at BIM82855.

Guidance on the position where a third party takes over the LLP, but the business continues in the LLP can be found at BIM82870.

Guidance on the position when an external party or parties injects capital into the partnership, such as a Private Equity firm, can be found at BIM82880.

Guidance on the position when the UK partnership is seeking to raise finance by issuing shares in a corporate partner to be traded on a stock exchange can be found at BIM82890.

Guidance on the position where an LLP has a structure that approximates to a share scheme can be found at BIM82900.

Guidance on the position when the UK partnership is a member of a wider International grouping can be found at BIM82910.