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  • Tax

    Hybrid structure: owner, partner and Ltd

    Yes, it's an article off-selling Tony Gimple so that Mark Alexander can sell his own tax consultancy service, which might include "hybrid" advice, but he's not sure yet which side of the fence he is on ... BTW Mark Alexander is not a qualified tax advisor.

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    I know from speaking to a few LLs that this is quite big topic at the moment so I would be very interested to hear about any success stories - or nightmares for that matter!

    My wife and I have been running our mixed property portfolio as a partnership for 30 years and we're currently contemplating the combo/hybrid LLP/Ltd co route. This is not necessarily to combat s24, due to our gearing being very low and 50% of our loan interest will still be fully allowable because of the commercial aspect. Our main motivation is to bring our grown-up children into the business and to allow them to continue after our death (GULP!!!) without having to worry about IHT.

    From my layman's understanding of a brief reading of one of the links to HMRC's take on mixed partnerships, I found them to appear to be quite family-friendly. Or should I have substituted 'layman's' with 'stupid bloke's'?

    Great website!

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    Has anyone followed up on this hybrid scheme, not entirely convinced it would stand up to scrutiny.

    It seems to good to be true, ticks the IHT box, corporation tax etc...

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    My own finding are If it sounds too good to be true it normally is

    I don't think such schemes work

    If you want to avoid S24 its a full sale and buy back into your Company

    and its not for every one


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    Learn Change and Adapt ?????

    I would be inclined to spend a bit of time reading this HMRC manual before entering into such an arrangement

    https://www.gov.uk/hmrc-internal-manuals...hip-manual

    Particularly this page

    https://www.gov.uk/hmrc-internal-manuals...al/pm40300

    My take from this is that it is well and truly on HMRC's radar and anyone contemplating such an arrangement should go into it only on a fully informed basis


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    I listened to the podcast about this and kind of understood some of the logic behind it, but wouldn't be able to explain it to someone else.

    However, I do remember thinking that it came across as a loophole and loopholes can easily get shut down.

    When I found out that Tony Gimple charges 14,000 + to set this up, I thought that was an awful lot of money for a loophole... I'm probably wrong, but don't want to pay 14k to find out...

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