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Umbrella LLPs

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30 July 2008
Issue: 4169 / Categories: Forum & Feedback
Is the rental income of each limited liability partnership ring fenced?

I am involved with some property investment limited liability partnerships. We are trying to decide the best way to structure our activities in the light of ITTOIA 2005 s 859(2).

I am aware that because of ITTOIA 2005 s 859(2)(b) any rental income that is received from a limited liability partnership (LLP) is kept separate from any rental income that I have in my personal capacity and therefore the losses of one are not available for offset against current year profits of the other.

I believe this also means that if I have an investment in two LLPs these are kept separate from each other (and from my personal property income) and again there is no scope for offsetting losses of one LLP against profits of another LLP.

However what if the LLP structure is more complicated? Suppose I invest in and become...

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