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
- Fees to charge for Auto enrolment Pension for small Employers 192 2
- PPR on a development? 213 4
- S445 tax V's new dividend tax 279 4
- PAYE – Directors NI 300 7
- Do I walk away from these accounts? 867 19
- Private Residence Relief 1,770 15
- Cloud accounting package 163 1
- Incorporation after the start of trading 1,013 39
- Setting up offshore to avoid paying VAT 497 15
- Legal structure of a group of friends producing a free newspaper 292 6
- Offshore company (Guernsey / Isle of Man) 183 3
- Next Move 380 12
- Ltd Co and 'grant' income 408 7
- when to file SA return if closed SA in the middle of the year 219 4
- Large PAYE tax refund to Employee 345 3
- Personal Tax Accounts. Are we all doomed. 717 10
- Accounts treatment of assets at cessation date 298 10
- Seeking advice: Vehicle usage 198 3
- Accountant won't release working papers 2,264 34
- Casual Driver 286 4
- Self employed and HMRC Worldwide Subsistence Rates 634
- VAT on Export Outside EU and Conditional Sale 395
- Acrobat Checkbox Help for New 64-8 395
- Property letting & CAs 377
- Interest paid - do new rules affect Tax Credits? 373
- 2015 tax year end 373
- FCA regulated company in a small group 336
- What's happened to Smith's Taxation 234
- MLR and benefitting from the disclosure 225
- Market Invoice (P2P invoice discounting) tax treatment 222