MFA Submits Comments on UK Tax Consultation Document

The MFA submitted comments to the UK consultation document on certain tax aspects of partnerships. The MFA's suggestions include:

• Adopting a single test to determine when a member of an LLP would be deemed a "salaried member";
• Eliminating the additional proposed test that would create an ambiguous and uncertain test for determining when an individual is a "salaried member";
• Providing additional guidance on how HMRC plans to interpret and implement the test and associated anti-avoidance rules;
• Clarifying that rules related to the allocation of profits and losses will not prevent partnerships from engaging in arrangements that have a legitimate business rationale; and
• Applying its rules in a manner that avoids double taxation and that permits taxpayers to reclaim taxes paid on amounts that are never received.

See: MFA Comment Letter; MFA Press Release.