What does Taxation of Partnerships and Private Capital Structures cover?
It addresses the UK tax issues for partnerships and LLPs, as well as investment fund partnerships and related private capital structures. It explains both the technical rules and their practical application, including how HMRC approaches and positions key issues.
Who is this book for?
It's written for advisers working with trading and professional partnerships/LLPs and the investment management/private capital community — including lawyers and tax professionals who need a single reference covering partnership taxation alongside the specialist regimes that frequently arise in funds and carried interest structures.
What are the key "private capital" regimes discussed?
The book contains extensive coverage of the special regimes that supplement the core partnership rules for investment management, including disguised investment management fees (DIMF), carried interest, and income-based carried interest (IBCI).
What's new in the 2nd edition?
The 2nd edition is a significant rewrite, updated for new case law and legislation since 2021, like Pillar 2, and for developments in market practice and HMRC's changing positions.
Does the book include coverage of offshore/international partnership structures?
Yes. It includes an international perspective and discusses the UK taxation of partnerships and structures with an offshore element, reflecting the cross-border issues that commonly arise for funds and partnership-based private capital arrangements.
