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How do I test if trade carried on in the UK or not

LLP profits for non-resident partner. How to determine where the LLP trade is carried on

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Hi

My understanding is that non-UK source profits made by an LLP will not be subject to UK tax unless the members are UK resident (which one of mine is not)

How do you determine the "source" of the profits made?

The LLP is an internet business.  100% of the turnover is commission received from large international companies (most likely US companies, but with offices in the UK).

Thank you

Ryan

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By Haemorrhoid
15th Feb 2017 14:41

This is what you need:
http://www.legislation.gov.uk/ukpga/2005/5/section/6?view=plain

And I know what your next question is going to be!

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Replying to Haemorrhoid:
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By RM1974
15th Feb 2017 16:09

Thank you for the response.

What I'd like to know is how you determine where "the trade is carried on"?

There are two partners. One is UK domicile and UK resident the other is UK domicile but non resident. So control is 50/50 UK/Non-Uk.

The LLP registered office and trading address is in the UK.

Turnover and profit derives from trade with customers not based on the UK.

Thanks again.

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