Paragraph 2

In Part 17 of CTA 2009 (partnerships) after section 1273 (limited liability partnerships) insert—

Limited liability partnerships: salaried members

1273A

(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.