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Finance Act 2014
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2In Part 17 of CTA 2009 (partnerships) after section 1273 (limited liability partnerships) insert—
“1273ALimited liability partnerships: salaried members
(1)Subsection (2) applies at any time when section 863A(2) of ITTOIA 2005 (limited liability partnerships: salaried members) applies in the case of an individual (“M”) who is a member of a limited liability partnership in relation to which section 1273(1) applies.
(2)In relation to the charge to corporation tax on income, for the purposes of the Corporation Tax Acts—
(a)M is to be treated as being employed by the limited liability partnership under a contract of service instead of being a member of the partnership, and
(b)accordingly, M’s rights and duties as a member of the limited liability partnership are to be treated as rights and duties under that contract of service.”
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