where the PSR in an LLP is 5% to individual 95% corporate member and ITTOIA 2005 s850C applies - does the LLP tax return still show the 5:95 split and if so where do we make the anti avoidance adjustments on the individuals tax return?
Related resources
Replies (2)
Please login or register to join the discussion.
Exactly
You have to make the LLP partnership return exactly as you would have done without the mixed partnership rules.
You then make the adjustment in box 9 of the partnership pages of the tax returns of the affected individuals.
The CT comp for the corporate member is odd too. You have to firstly deduct the accounting profit and add the taxable profit share (as you always would have done before the new rules) and then deduct the aggregate of the amount now being taxed on the individual partners.
All accompanied, of course, by white space disclosure, as HMRC won't even begin to understand it!
many thanks MBK
we had opted for box 19 but on balance we prefer your suggestion of Box 9