An LLP and its members are required to register with HM Revenue and Customs (HMRC).
Partnerships, including limited liability partnerships (LLPs), are "transparent" for tax purposes. This means that the partnership itself is not subject to income tax. Instead, partners pay tax on the partnership's profits in their respective shares.
In general, for tax purposes, it is recognized that the partners earn profits/income as they are generated by the partnership (without any distribution).
In doing so, the partnership files tax returns. Both the partnership and the partners get on the tax rolls, the partners are individuals - as self-employed. The self-employed also pay social contributions.
The partnership gets on the VAT books, reports and pays VAT in the usual manner.
If the partners in the LLP are not UK tax resident and the activities of the LLP do not take place in the UK, there is no income from UK sources, there may be no UK tax consequences.
Individuals who are UK residents and whose permanent residence (domicile) is in the UK are liable to pay income tax on their worldwide income. UK residents without a UK domicile can benefit from reduced taxation of income and assets outside the UK. If the resident is not domiciled in the UK, taxation may be different.
Individual income tax is levied at progressive rates with some exceptions and peculiarities:
Dividend income is taxed at rates from 8,75% to 33,75%, depending on the amount of the dividend.
There are non-taxable thresholds for certain types of income.
Capital gains up to GBP 12 300 are tax exempt.
Profits over this amount and up to GBP 37 500 are taxed at the rate of 10%.
Amounts above this limit are taxed at the rate of 20%.
Profits from the sale of housing, which are not exempt from taxation, are taxed at 28% and 18%, depending on the amount of profit.
UK tax resident company pays income tax on its worldwide income.
Profits of foreign permanent establishment may be excluded from the tax base at the option of the taxpayer. Non-resident companies pay tax on profits earned in the UK.
The basic rate of income tax is 25%.
Capital gains are taxed at the normal rate of income tax.
Gains from the sale of 10% or more of the shares in a company are generally not taxable. This exemption does not apply to sales of companies acquired in the previous year or to companies not in business.
In most cases, dividends from foreign sources, as well as dividends from companies in the UK, with some exceptions, are not taxed.
No withholding tax is imposed on dividend payments.
Tax is withheld on payments of interest and royalties at a rate of 20%. There are exceptions for some royalties and interest, such as interest on circulating Eurobonds, interest on short-term (not more than one year) loans, etc.
Tax may be withheld on certain other income payments.
The standard rate of VAT is 20%.
A reduced VAT rate of 5% is levied on certain types of goods and services.
Stamp duty may be charged at a rate of 0,5% (1,5% in some cases) on stock transactions.
Stamp duty of 5% may be payable on the acquisition of non-residential property. Stamp duty on the purchase of residential property is 15% (if the purchaser is a natural person and the property to be purchased is the only home, the tax is charged on a progressive scale up to 12%).
As of April 1, 2021, an additional 2% will be charged if the purchaser of the residential property is a non-resident.
Stamp duty is also levied on rental properties.
There are special rules in Scotland and Wales.
The local authorities levy taxes on real estate located in the respective region.
Also if the owner of residential property is not an individual, and the value of the property is GBP 500 000 or more, then property tax (ATED) is paid at the rates set in pounds sterling and depends on the value of the property. This tax may not be levied if the property is rented out, and in some other cases.
Inheritance Tax (IHT) is levied on the value of the deceased taxpayer exceeding GBP 325 000. This tax can also be levied during the taxpayer's lifetime on certain transactions (the most common case being the transfer of property to a trust.
In addition, the transfer of property no earlier than 7 years before the taxpayer's death is also subject to this tax.
Persons without domicile (or imputed domicile) pay this tax on UK property.
Transfers of property between spouses both during life and posthumously are not subject to this tax unless the spouse with a domicile transfers the property to the spouse without a domicile and the value of the property exceeds GBP 325 000.
Such contributions (NIC) are paid by employers, employees and the self-employed.
NIC at a rate of 12% applies to employee remuneration between GBP 242 and 967 per week and at a rate of 2% on remuneration above this amount.
Employers pay NIC on employee remuneration at 13,8%.
The self-employed pay NIC at a rate of 9% on income between GBP 12 570 and 50 270 per annum and at a rate of 2% on the excess.
UK companies may be required to pay tax on the profits of controlled foreign companies. The main purpose is to tax profits that have been artificially taken out of taxation in the UK.
A number of tests are applied to determine the tax liability. In particular, it is determined whether the profits of the foreign controlled company are generated in connection with significant functions performed in the UK.
There are various exceptions.
The transition period for the UK's exit from the EU ended at the end of 2020. The parties had time before the end of the year to conclude a trade and cooperation agreement, which provides, among other things, for the non-application of customs duties in mutual trade, provided certain conditions are met.
The UK will no longer have access to EU directives on subsidiaries and parent companies, interest and royalties, and reorganizations. However, this may be largely offset by the existence of bilateral tax agreements between the UK and EU member states.
Changes in the relationship mean additional administrative procedures, for example, UK companies selling goods to the EU may need to register for VAT purposes in different EU countries.
There are other consequences of leaving the EU to consider.
The UK has signed 132 Double Tax Treaties (DTC) and 21 Tax Information Exchange Agreements (TIEA) with the following jurisdictions:
132 DTCs: Albania, Algeria, Argentina, Armenia, Australia, Austria, Azerbaijan, Bahrain, Bangladesh, Barbados, Belarus, Belgium, Belize, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Brunei Darussalam, Bulgaria, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Croatia, Cyprus, Czech Republic, Côte d'Ivoire, Denmark, Egypt, Estonia, Falkland Islands (Malvinas), Faroe Islands, Fiji, Finland, Former Yugoslav Republic of Macedonia, France, Gambia, Georgia, Germany, Ghana, Greece, Grenada, Guernsey, Guyana, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Jamaica, Japan, Jordan, Kazakhstan, Kenya, Kiribati, Korea (Republic of), Kosovo, Kuwait, Kyrgyzstan, Latvia, Lebanon, Lesotho, Libya, Lithuania, Luxembourg, Malawi, Malaysia, Malta, Marshall Islands, Mauritius, Mexico, Moldova (Republic of), Monaco, Mongolia, Montenegro, Montserrat, Morocco, Myanmar, Namibia, Netherlands, New Zealand, Nigeria, Norway, Oman, Pakistan, Panama, Papua New Guinea, Philippines, Poland, Portugal, Qatar, Romania, Russian Federation, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, Solomon Islands, South Africa, Spain, Sri Lanka, Sudan, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Trinidad and Tobago, Tunisia, Turkey, Turkmenistan, Tuvalu, Uganda, Ukraine, United Arab Emirates, United States, Uruguay, Uzbekistan, Venezuela, Viet Nam, Zaire, Zambia, Zimbabwe.
21 TIEAs: Anguilla, Antigua and Barbuda, Aruba, Bahamas, Belize, Bermuda, Dominica, Gibraltar, Grenada, Guernsey, Isle of Man, Jersey, Liberia, Liechtenstein, Nederlandse Antillen, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, San Marino, Turks and Caicos Islands, Virgin Islands, British.
The UK has also signed and ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The Multilateral Convention entered into force for the United Kingdom on October 1, 2018.
In the UK there are no exchange controls.
