Tax analysis: In Quillan, the First-tier Tax Tribunal (FTT) allowed the taxpayer’s appeal, finding that his director loan account balance was neither written off nor released for the purposes of section 415(1) of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005) on the liquidation of the company, contrary to HMRC’s guidance on this area in its Company Taxation Manual.
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Taxation of UK LLPsForthcoming change relating to Class 2 (self-employed) National Insurance contributions (NICs): at Autumn Statement 2023, on 22 November, the government announced that mandatory Class 2 NICs will be abolished with effect from 6 April 2024. For more information, see News Analysis:
Taxation of general partnershipsThis Practice Note is about the tax treatment of a general partnership formed under English law (as opposed to a limited partnership, a limited liability partnership (LLP) or a partnership formed under Scottish law—for more on these other types of partnerships, see
What are the potential tax implications for an unincorporated association incorporating into a company limited by guarantee and transferring all of its assets into said company?We have assumed that the assets and all relevant parties are in the UK.An unincorporated association is subject to
Would a limited liability partnership be classified as a company for the purposes of determining connected persons under section 1122 of the Corporation Tax Act 2010? What about a limited partnership?Section 1123 of Corporation Tax Act 2010 (CTA 2010) defines ‘company’ for the purposes of CTA 2010,
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