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Contents

Official guidance
Partnership Manual

PM213000 · Mixed member rules

  • PM214000 · Overview
  • PM216000 · Who is a non-individual partner
  • PM217000 · When do the rules apply?
  • PM218000 · Condition X
  • PM219000 · Condition Y
  • PM220000 · Appropriate notional profit
  • PM221000 · The appropriate notional return on capital
  • PM222000 · The appropriate notional consideration for services
  • PM223000 · The appropriate notional consideration for services: restriction
  • PM224000 · The power to enjoy
  • PM225000 · Connected parties
  • PM226000 · Arrangements to secure corporation tax rather than income tax treatment
  • PM227000 · Enjoyment Conditions
  • PM228000 · Is the profit share influenced by the power to enjoy?
  • PM229000 · Relevant tax amount
  • PM230000 · Reallocations: Individuals
  • PM231000 · Reallocations: Non-individuals
  • PM232000 · Payments by the non-individual out of its reallocated profit share
  • PM233000 · Interaction with AIFM deferral arrangements
  • PM234000 · Anti-avoidance
  • PM235000 · Other related guidance
  • PM236000 · Businesses transferred to the partnership
  • PM237000 · Businesses transferred to the partnership: Examples
  • PM238000 · Takeover of the LLP
  • PM239000 · Private equity investment
  • PM240000 · Share issues
  • PM241000 · Pseudo share schemes/membership benefit schemes
  • PM242000 · International structures
  • PM243000 · Commencement
  • PM244000 · Excess loss allocation rules
  • PM245000 · When do the restrictions apply?
  • PM246000 · The effect of the restrictions?
  • PM247000 · Transitional provisions
  • PM248000 · Close companies: loans to participators and arrangements conferring benefit on participator
  1. Mixed member rules: contents
  2. Other related guidance

PM235000 | Other related guidance

From HM Revenue & Customs · Partnership Manual

The following sections look at the application of the excess profit allocation rules to specific issues.

Guidance on the position when an existing business carried on by someone else is transferred to an LLP can be found at PM236000.

Guidance on the position where a third party takes over the LLP, but the business continues in the LLP can be found at PM238000.

Guidance on the position when an external party or parties injects capital into the partnership, such as a Private Equity firm, can be found at PM239000.

Guidance on the position when the UK partnership is seeking to raise finance by issuing shares in a corporate partner to be traded on a stock exchange can be found at PM240000.

Guidance on the position where an LLP has a structure that approximates to a share scheme can be found at PM241000.

Guidance on the position when the UK partnership is a member of a wider International grouping can be found at PM242000.

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