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
- I know ... 1,209 4
- What password safe app does anyone recommend? 678 18
- Tax on principal private residence 214 4
- extra 5p per mile for passengers 218 3
- What are the typical deductible expenses? 241 2
- recovery of S455 on informal winding 127 1
- Does unpaid share capital attract s455 liability? 216 4
- Personal pension contributions 245 4
- Claiming tax relief on goodwill 316 4
- RTI Filing 946 20
- Staff entertaining or not? 253 3
- Sole Trader Start Up- Employment Help 392 5
- CGT and PPR and Lettings Relief? 213 4
- IR35 and working for an EU company 128 1
- Shareholder Loan write off 449 21
- Getting advice from HMRC 652 14
- Tax calc and NIC 214 2
- How long is filing an FPS meant to take ? 1,834 29
- German wanting to pay UK tax 354 3
- Employment allowance and service companies (outside IR35) 424 13
- Residential Property Purchase Above £750K 699
- Using Sage with Sofa Categories 469
- One man Company and closing payroll scheme as none paid 307
- Does anyone have an unwanted ICAEW wooden plaque? 270
- Goods shipped inter EU and VAT Reporting 243
- growth voucher supplier 216
- Sage 200 and Access Dimensions reviews 183
- VAT on Gaming Machines 168
- transferring simply accounting 2010 from xp to windows 7 156
- Papilio UK Equity Release Mortgages Ltd 155