Partnership tax rules

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HMRC have published an updated technical note on mixed membership partnerships, Alternative Investment Fund Managers (AIFM), and transfers of assets & income streams through partnerships; as well as a separate technical note on salaried members say Harris & Co accountants Northampton

The revisions to the technical notes are a result of changes to draft legislation following feedback received on HMRC’s consultation on how to change two aspects of partnership tax rules: the disguising of employment relationships through limited liability partnerships (LLPs) and the tax-motivated allocation of business profits or losses in partnerships (not just LLPs) involving mixed members (typically individuals and corporate members).

The amended legislation is part of Finance Bill 2014 published on 27 March 2014.

The revised technical note and guidance on mixed membership partnerships; alternative investment fund managers; transfer of assets and income streams through partnerships, can be found here. The revised technical note and guidance on salaried member rules can be found


The consultation outcome document is available here.

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