It’s a wrap

KEY POINTS

• The existence of a business will be critical to the use of a partnership in a private client context.
• Uncertainty over capital gains tax and inheritance tax treatment can cause problems.
• The business property relief trap – care is required when considering how shares are held.
• The tax treatment of transfers into partnerships.
• The use of partnerships as wrappers for luxury assets and properties.
• Partnerships can offer advantages if a non-domiciled taxpayer uses the remittance basis.

Partnerships are flexible creatures and often known to private clients from their business interests. They are widely used in the private equity context and for trading purposes.

However in the “pure” private client arena they are often considered but then rejected in favour of other structures.

Here ...