ARTICLE · 20 MARCH 2013

Partnerships: In HRMC's Sights

Deloitte

Explore more from Deloitte

As a choice of business vehicle, partnerships offer a level of flexibility which continues to encourage their increasing use across a range of sectors beyond their traditional use by professions and small businesses.

United KingdomTax

Deloitte Tax Group

Author LinkedIn connections

As a choice of business vehicle, partnerships offer a level of flexibility which continues to encourage their increasing use across a range of sectors beyond their traditional use by professions and small businesses. The other sectors include including hedge funds, film partnerships, the property sector and the corporate business world generally. The perception at HMRC is that, in some cases, this flexibility has been taken too far and "the misuse of partnership rules has become a feature of many avoidance schemes". The Chancellor has therefore announced an intention to consult, this spring, on new legislation designed to target the use of partnerships to artificially reduce tax liabilities. Two specific areas of review have been highlighted:

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Working From Home And The Hidden Risks Of A Permanent Establishment

United KingdomTax

Under Investigation: Tax Enquiries In The Construction Industry

United KingdomTax

Kingsley Napley LLP

HMRC's New Anti-Avoidance Information Powers

United KingdomTax

UK Prize Draws: HMRC Scrutiny Of VAT Treatment

United KingdomTax

The Autumn Budget: Why Uncertainty Is Now The Biggest Cost For Business

United KingdomTax

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Corporate Tax
- Income Tax

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

What Are Exit Taxes And How Do They Work?

As the UK anticipates its first Budget under Andy Burnham's premiership on 28 October 2026, questions arise about whether 'Manchesterism' will introduce an exit tax regime. This analysis examines how different jurisdictions—from Canada's deemed disposal system to France's targeted charges on substantial holdings—tax individuals leaving their borders, and explores what form a UK exit tax might take if implemented.

US FATCA In The UK - Updated HMRC Guidance Notes Released

Today HMRC released updated Guidance Notes on implementing FATCA in the UK.

United KingdomTax

Andy Burnham’s Property Tax Reform: What High Net Worth Individuals Need To Know

Burnham has consistently advocated for replacing council tax and stamp duty with a land value tax - an annual levy charged on the value of the land itself, rather than the buildings on it.

United KingdomTax

Capital Gains Tax And Private Equity Tax Under A Labour Government: What We Know So Far

Labour plans to defer major tax changes until the autumn Budget. Key potential changes include raising capital gains tax, altering private equity taxation, and possibly integrating capital gains and inheritance tax rules.

United KingdomTax

UK ‘Windfall’ Bank Tax Would Worsen An Already Complex System

UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.

United KingdomTax

Frequently Asked Questions About IRS Clearance And Form 706-NA

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.

Lester Aldridge LLP

Autumn Budget 2024 - Capital Gains Tax

The Chancellor's 2024 Budget introduced moderate changes to Capital Gains Tax (CGT). Rates for basic and higher rate taxpayers increased to 18% and 24%, respectively. Business Asset Disposal Relief and Investors' Relief rates will rise from 10% to 18% by 2026, with anti-forestalling provisions. Rates for residential property disposals remain unchanged.

United KingdomTax

Travers Smith LLP

Taxation Of Earn-Outs On Business Sales: Capital Gain Or Disguised Salary?

HMRC is increasing scrutiny of earn-out arrangements, particularly where founders remain involved in the business after completion and deferred consideration depends on future performance of the target company.

United KingdomTax

Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.

European UnionTax

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.

United KingdomTax

Macfarlanes LLP