UK LLP and Foreign equity in foreign company
A Limited Liability Partnership registered in UK owns 30% of equity of a foreign Limited Liability Company, let’s call them RF1. RF1 gained profit and issued a Protocol of General Meeting and distributed dividends making certain amount of dividend income payable to a UK holding and investment Partnership. All of this happened in the same accounting period which ended on 31 July 2012 falling into the tax year 12-13. The dividend income was never actually paid and remains an asset (a receivable) of the Partnership. All of the Partnership members are companies non-resident in UK, who do not trade in the UK.
1. What is the total tax burden of the Partnership’s members? I believe that this would be 10% of the payable dividend income split between the partners in proportions set out in their Partnership Agreement?
2. Return for which tax year should declare the dividend income, 12-13 or the future tax year in which the dividend income will be paid?
3. How is the Partnership supposed to declare the dividend income? My assumption is that it would go to the foreign pages of SA800 tax return leaving the Trade and Professional Income pages of the return with zero-balance (blank).
4. How are the non-resident company members supposed to declare their profit? Our assumption is that each of the partners should receive a UTR in UK and file a CT600 (or an SA800?) tax return stating their share of the dividend income as Profits chargeable to corporation tax.
5. What impact would it have on the Partnership's taxation if they purchased additional shares of the RF1 Company so as to increase their share of equity from 30% to 49%?
I would be grateful for any pointers. Many thanks
- IR35 deemed payment and dividends - practical considerations 149 3
- VAT on Hire Purchase 168 2
- "Audit Report" 64 1
- Annual tax investigation cover fee? 470 13
- Coding Notice 226 6
- UK company paying dividend to foreign shareholder 240 6
- New business - journal entries 409 22
- Is CGT roll over relief available for let property 221 3
- Payroll software 644 16
- Statutory accounts, current company address, or one that was correct at EOY? 266 5
- Are there Special Rules for Agencies? 396 10
- 100% Annual investment allowance on luxury cars 731 18
- B2B vat in the EU 187 4
- Samadian effect on self employed student support workers 197 4
- Changes to class 2 NIC's 226 3
- Client RTI Shows payments not his 194 4
- LLP as member of LLP 135 1
- Why should I retain membership? 2,838 48
- Alerting clients versus walking away from clients 514 7
- Vat 306 7
- Auto enrolment excuses 866
- Feedback on accounts production software for IFRS 721
- Add T&Cs to Sales Order in Sage 409
- Social investment tax relief 219
- Digita Hosted Software 213
- Call Centre Data Costs 200
- accounting for this transaction 192
- Buying goods in US and selling them to company in US 171
- Problems with Sage 50 Payroll v21(2015) 168
- Travel costs and contractors 167