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The UK PE of a non-resident company acquiring an interest in a trading partnership is not treated as acquiring its share of intangible fixed assets of the partnership according to the FTT in Bloomberg. Loan administration services are standard rated as debt collection because the loan administrator did not also advance the loans according to the FTT in Target Group Limited. A consultation begins on the reform of limited partnership law to limit the risk of misuse of limited partnerships. In Investec, the UT concludes that sums paid by way of capital contributions to the leasing partnerships should be disallowed as not wholly and exclusively for the purposes of Investec’s trade. The Court of Appeal concludes that the FTT made errors of law which the UT wrongly found to be immaterial and remits the Newey (t/a Ocean Finance) case to the FTT to direct itself correctly in law.
This article was first published in the 11 May 2018 edition of Tax Journal.