.png)
.png)
In a case concerning a tax planning arrangement Hill Samuel Investments appealed against amendments to its corporation tax self assessment returns for the years ended 31 December 2000 and 2001.
It had two separate partnership agreements with two unrelated US partnerships. Under these agreements the appellant became a partner after making a £350 million contribution to each partnership’s capital.
While a partner the appellant received income from the partnerships net of US tax. In both cases it was agreed that the appellant would retire from the partnerships after a set period with the parent companies of the US partnerships taking over and repaying the appellant’s interest in the partnerships.
The partnerships made elections for US tax purposes (known as check the box elections) to be treated as corporations rather than partnerships.
During the period of the investment no UK tax was paid on the...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
