Pamela Sayers discusses the immediate and longer-term
implications of the changes to LLP taxation.
Despite intense lobbying, even in the last few days leading up
to 5 April 2014, the new proposals for the so-called 'salaried
member' rules went ahead. While revised guidance published by
HMRC on 27 March provides greater clarity on some aspects,
uncertainty remains for many firms as to whether they might
'fail' one of the conditions to allow their partners to
remain as self-employed for income tax purposes.
Firms looking for additional comfort by applying to HMRC's
non-statutory clearance team are unlikely to receive a response
until late summer. HMRC has stated that it will not respond to
applications until the Finance Act 2014 has received Royal Assent,
probably in mid-July.