Taxation of Partnerships and Private Capital Structures addresses in detail the technical and practical UK tax issues that arise in relation to trading and professional partnerships and LLPs and in relation to investment fund partnerships and related structures. As well as discussing the UK tax landscape for all types of partnerships and private capital structures, the book contains an extensive discussion of the special regimes (including those for disguised investment management fees, carried interest and income based carried interest) which supplement these rules for the investment management community.
The UK treatment of partnerships is still largely non-statutory while the tax treatment of flows to investment managers has been subject to extensive changes (and a significant amount of related case law) since 2014. The book helps demystify these complex areas of tax by offering an explanation of the technical issues, reasoned views on the practical application of these rules and the positioning of HMRC.
The second edition represents a significant rewrite and is updated to reflect the myriad of new case law and legislation since 2021 as well as the experience of the authors and the changing positions of HMRC since then.
The new edition also includes 3 new chapters covering:
- The offshore fund rules
- Pillar 2
- The UK Qualifying Asset Holding Company (QAHC) regime
