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Are there any tax consequences for converting from limited liability partnership to ‘normal’ partnership?

Question:

An limited liability partnership (LLP) client wants to convert to a normal partnership. What would be the main tax considerations? The only LLP asset is a lorry. Both partners have drawings in excess of profits and trade would continue the same with same partners. 

Arthur Weller replies:  

Generally, a LLP is transparent for tax purposes, so that the actions of the LLP are considered to be the actions of the partners. There is an exception to this where a liquidator is appointed on a winding up of the LLP. But on an informal winding up, without the appointment of a liquidator, this does not apply. See HMRC’s manual. So there should be no capital gains tax issue for what you are planning. 

An limited liability partnership (LLP) client wants to convert to a normal partnership. What would be the main tax considerations? The only LLP asset is a lorry. Both partners have drawings in excess of

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This question was first printed in Business Tax Insider in August 2020.