RPSM04103060 - Technical Pages: Taxation: Scheme investments: Property investment LLPs
Property investment LLPs
A property investment LLP is defined in section 842B ICTA 1988 as “a limited liability partnership whose business consists wholly or mainly in the making of investments in land and the principal part of whose income is derived therefrom”.
Income tax
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[s 186(2)] |
Where a registered pension scheme receives income, including any relevant stock lending fees, in their capacity as a member of a property investment LLP the normal taxation exemptions in respect of that income do not apply. Any such income will be assessable to income tax.
Capital gains tax
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[s187(7)][s271(12) TCGA 1992] |
Where a registered pension scheme makes a gain arising from the disposal of an investment in their capacity as a member of a property investment LLP the normal exemption in respect of capital gains tax in relation to investments held for the purpose of registered pension schemes does not apply. A gain arising from the acquisition or disposal of assets held as a member of a property investment LLP is a chargeable gain liable to capital gains tax.
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Glossary (RPSM20000000) |
