HM Revenue & Customs (HMRC), the UK tax authority, published a consultation document in late May focusing on two aspects of the taxation of partnerships and in particular limited liability partnerships (LLPs), one of the preferred structures for hedge fund management companies.
The two aspects covered are “disguised employment” and “profit and loss allocation schemes”.
The consultation is currently at the centre of discussions between the UK Treasury, HMRC, the Financial Conduct Authority (FCA)
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