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
- valuation of vehicles 172 10
- Is there no lower level to the work a lawyer would take on. 520 17
- RTI Mess 462 9
- directors loan 54 3
- Tax on LLP members drawings not covered by future profits 327 13
- Mortgage Interest - Tax Deductible 321 3
- Scientist switch to accountancy - work experience? 963 27
- CIS not deducted 225 4
- Money Laundering Manual 163 3
- Business only use of company car 524 20
- Penalties for late PAYE scheme 100 1
- Paying PAYE by Direct Debit 483 17
- Worst corporate entertaining events? 1,054 8
- Sage Accounts in a mess 459 9
- New Company reviews please 361 9
- Buy to let investors and the budget changes. 427 6
- Tax efficient vehicle 603 11
- CGT on Let Property 198 3
- How best to split income on a Buy To Let - married. How do you decide beneficial ownership 377 6
- Dormant company late with their CH submission 459 13
- RTI Rollback to delete incorrect data 269
- Motor Traders Assistant Bookkeeping Programme queries 234
- Vouchedfor.co.uk 229
- Tracesmart/Lexis Nexis AML software? Any opinions? 207
- Expenses Software 184
- Any thoughts on Capium? 183
- VAT FRS percentage for sales person? 173
- cgt quoted shares losses 169
- Sage Compatible P60's Self Seal 168
- auto enrolment 167