PM260300 - Compliance and PAYE failure
If HMRC reviews the position and it is found that the LLP has failed to treat a member as a Salaried Member, then this would be a PAYE failure.
The result would be that the LLP, as the employer, would be liable to pay over the amount that should have been deducted from the amount that was actually paid to the employee.
For further guidance on this, please see the Compliance Operational Guidance at COG913010.