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HMRC internal manual

Employment Status Manual

From
HM Revenue & Customs
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Salaried Members: Global Structures: Capital of the LLP

The legislation looks at the UK LLP in isolation. As a result, capital invested in another member of the structure is not taken into account, even if the UK LLP receives funding from that body.

 

Example

This example shows how the LLP should be considered in isolation.

The ABC US LLP is the worldwide “parent” of the ABC firm, which operates in the UK through the ABC UK LLP and which it funds through a mixture of capital and loans.

A is a member of a US LLP, who is seconded to work in the UK, becoming a member of the UK LLP.

A has capital invested in ABS US LLP but not ABS UK LLP.

As the test applies to the UK LLP in isolation, A satisfies Condition C as he has contributed no capital to ABS UK LLP.