CONTENTS
Terms of Reference
Abstract
Chapter 1: Introduction
Chapter 2: Partnerships-General Background
Types of Partnership
General Partnerships
Limited Partnerships
Limited Liability Partnerships
Partnership Facts
Taxation of Partnerships
Review of Partnerships: Interim Report
Conclusions
Recommendations
Chapter 3: The Consultation and the Draft
Legislation
Limited Liability Partnerships
The Limited Liability Partnerships Act 2000
The Budget Announcement and the First Consultation
The Response to the First Consultation and
the Draft Legislation
Views on the Draft Legislation
Mixed Membership Partnerships
The Budget Announcement and the First Consultation
The Response to the First Consultation and
the Draft Legislation
Views on the Draft Legislation
AIFM Partnerships: Profit Deferral Arrangements
A New Mechanism to Tax Deferred Profits
Transfers of Assets and Income Streams Through
Partnerships
Estimated Yield From Draft Legislation
Chapter 4: Salaried Members of Limited Liability
Partnerships
The Approach of the Legislation: Case Law
or Legislative Tests?
A Case Law Approach
The Legislative Tests
HMRC's View
Reconciling Views
Do the Three Conditions Achieve the Desired
Policy Outcome?
The General Scope of the Conditions
Objections to Condition A
Objections to Condition B
Objections to Condition C
Business Implications of the Three Conditions
Officials' Response
The Three Conditions: Other Points
Salaried Members' Provisions: Commencement
Exchequer Consequences of Delay
Table 1: Partnership Taxation Package: Estimated
Yield
Chapter 5: The Other Elements of the Partnerships
Package
Mixed Membership Partnerships
Objectives and Presentation
Draft Legislation
General Reactions to the Provisions
Scope: Which Existing Arrangements are Affected
by these Provisions?
The Legislation: Specific Issues
AIFM Partnerships
The AIFM Legislation
The Additional Yield
Transfers of Assets and Income Streams through
Partnerships
Chapter 6: The New Approach To Tax Policy-Making
Since 2011
The Tax Consultation Framework
Report on Finance Bill 2011: Recommendations
on New Approach
Previous Assessments of Performance Against
New Framework
The Partnerships Package and the New Approach
Developing Tax Legislation 2011-2014
Consistent Application of the New Approach
The Tax Policy Partnership
Scope and Reach of Consultations
Consulting Early on Potential Impacts
Consulting More Widely
Post-implementation Reviews
Strategic Context
Changes in a Broader Context
Changes and Road Maps
Chapter 7: Summary of Conclusions and Recommendations
Appendix 1: List of Members and Declarations
of Interest
Appendix 2: List of Witnesses
Appendix 3: Call for Evidence
Appendix 4: Glossary
Evidence is published online at http://www.parliament.uk/hlfinancebill
and available for inspection at the Parliamentary Archives (020
7219 5314)
References in footnotes to the Report are as follows:
Q refers to a question in oral evidence.
Witness names without a question reference refer
to written evidence.
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