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
- How could I be identified for VAT purposes in UK? 388 6
- IHT dilemma 1,141 17
- Tax return software for remote working 208 3
- Recharge for private use of a company car 329 7
- Are clients getting more stupid? 1,176 19
- CGT 318 14
- Problems with Sage 50 Payroll v21(2015) pension module 303 1
- Interest paid to non-UK company - Deduction 95 2
- Accounts production software license expiry & possible alternatives 254 5
- Compliance check 485 13
- sole trader accountant 749 14
- Entrepreneurs Relief 389 15
- Capital Allowances and Building Improvements 599 21
- More AE! 478 11
- How to classify an asset 138 3
- Ceasing in membership of ATT 269 2
- when a charity makes a donation.... 171 4
- EU eservices VAT change imminent 117 2
- Statement of turnover template 181 4
- CGT 115 1
- Auto enrolment excuses 1,068
- Feedback on accounts production software for IFRS 776
- Add T&Cs to Sales Order in Sage 456
- Digita Hosted Software 277
- Call Centre Data Costs 246
- Are any of you agents for doctors? 212
- Credit where credit's due....... 204
- Buying goods in US and selling them to company in US 196
- Married Couples Allowance wasted? 180
- Director phone costs 138