Consultation outcome

A review of two aspects of the tax rules on partnerships

From:
HM Revenue & Customs and The Rt Hon David Gauke
Published
20 May 2013
Last updated
28 March 2014 — See all updates
This was published under the 2010 to 2015 Conservative and Liberal Democrat coalition government
This consultation has concluded

Read the full outcome

Partnerships: A review of two aspects of the tax rules

PDF, 129 KB, 32 pages

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Detail of outcome

The government has confirmed it will take forward the partnerships proposals which will prevent avoidance and remove the tax advantages set out in the consultation document. This document summarises the response to the consultation and sets out the changes to the detailed policy design the government has made as a result of the feedback it received.

Legislation relating to mixed membership partnerships was published on 5 December 2013 and had immediate effect. The complete package of draft legislation was published on 10 December 2013 for consultation.

Original consultation

Summary

Seeking views on proposals for changing the partnerships rules in line with government’s principles and objectives for fairness and flexibility.

This consultation ran from
to

Consultation description

At Budget 2013, the Chancellor announced that the government would consult on changes to two aspects of the tax rules on partnerships in order to prevent tax loss arising from:

  • disguising employment relationships through limited liability partnerships; and
  • certain arrangements involving allocation of profits and losses among partnership members

Those changes will take effect from 6 April 2014.

The government would welcome views on the detailed design of the changes and on how to ensure that any impacts outside the specified targeted areas can be reduced without giving rise to uncertainty and avoidance.

Further information

National Insurance Bill 2013

Draft tax legislation and guidance

Alternative Investment Fund Managers: forms and guidance

Finance Bill 2014

Documents

Partnerships: A review of two aspects of the tax rules

PDF, 207 KB, 38 pages

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A review of two aspects of the tax rules on partnerships: Briefing

PDF, 26.4 KB, 2 pages

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Slides from partnerships review consultation open meeting

MS PowerPoint Presentation, 531 KB

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Updates to this page

Published 20 May 2013
Last updated 28 March 2014 + show all updates

  1. Legislation day technical notes and guidance about Salaried Member Rules and Mixed Membership Partnership, AIFMs and Asset Disposal Rules have been added to this consultation.

  2. added link to 'Finance Bill 2014: legislation, explanatory notes and guidance'

  3. Alternative Investment Fund Managers mechanism: election form and guidance has been added to this consultation.

  4. A link to the document collection which includes Salaried members: revised draft Finance Bill 2014 legislation, explanatory note and tax information and impact note has been added to this page.

  5. Updated to include a link to "Salaried Members Rules: revised technical note and guidance"

  6. Added a link to the finance bill 2014.

  7. Added a Further Information link under Draft tax legislation and guidance.

  8. Updated to include summary of responses and changes to the detailed policy design the government has made as a result of the feedback it received.

  9. Updated to include slides from open meeting

  10. First published.

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