Partnerships: partnerships, limited partnerships and limited liability partnerships: Limited liability partnerships: transfer of a partnership business to a LLP
For CG purposes the transfer of a business from a partnership to a LLP will not constitute a disposal by the partners of their interests in the original partnership’s assets unless their fractional interests in partnership assets are changed as a result of the transfer.
Annuities payable to retired partners of the original partnership
The transfer to a LLP of a partner’s rights to an annuity and/or the transfer of obligations to former partners in respect of annuities will not be regarded as a chargeable disposal by the original partnership provided that the rights remain substantially the same.
Similarly an annuitant who agrees to the substitution of a successor LLP as the payer of an annuity will not be regarded as making a chargeable disposal provided that the terms of the annuity remain substantially the same.
Guidance on annuities paid to retired partners is at CG28400.