The restrictions noted at ¶291-025 that apply to restrict loss relief for limited partners are largely mirrored in respect of corporate members of LLP in CTA 2010, s. 59–61.

The reliefs to which these provisions apply are as follows:

offset of the partnership trading losses against total profits under CTA 2010, s. 37; and

group relief under CTA 2010, Pt. 5.

Relief will be restricted to the extent that the cumulative relief allowed for any accounting periods during which the company has been a member of the LLP exceeds its ‘contribution to the LLP’ (CTA 2010, s. 59).

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.