LLM6130 - Conversion: Scottish limited partnerships: completing tax returns
Additional points need to be borne in mind in the two stage process of computing the partnership profits as though the SLP were both an individual Name and a corporate member (LLM6070). The sections below use the Partnership Tax Return for the year 2006-2007 as an example.
Savings, investment and other income
Apart from income from assets in ancillary trust funds (ATFs), taxed income (including foreign income from which UK tax has been deducted) should be returned for the period 6 April 2006 to 5 April 2007.
For untaxed UK and foreign income that arises on assets other than those in the partnership바카라 사이트™s ATF, the amount arising in accounting period ended 31 December 2006 should be returned.
Disposal proceeds of chargeable assets
Details of any disposals of partnership ATF assets should be included in the Partnership Capital Gains Pages, as partners who are individuals are assessable to capital gains tax on their share of the gains.
Where ATFs of SLP members of Lloyd바카라 사이트™s have been set up by one or more of the partners as individuals, any disposals should be reported by the individual partners on the Capital Gains Pages of their own SA Tax Return.
Income from ancillary trust funds
ATF income is trading income (LLM5040). For the income tax Partnership Statement, all income arising on ATF assets which is attributable to accounting period ended 31 December 2006 is included in the trading profits from membership of Lloyd바카라 사이트™s. Whether the fund is established by the partnership itself or provided for the partnership by any of its members, it is not shown separately as savings income or foreign income.
If ATFs of individual Names are made interavailable to the SLP, the income on these funds remains the Lloyd바카라 사이트™s trading income of those Names until the period of interavailability has finished, and should be returned by them on the Lloyd바카라 사이트™s Pages of their own Tax Returns.
Foreign income and tax
Pooling rules apply to foreign tax suffered where Lloyd바카라 사이트™s income is subject to income tax (LLM7030). Under these rules, the trading profit of the partnership is treated as a single item of foreign income, and the Lloyd바카라 사이트™s SLP foreign tax pool as the associated tax credit. The nominated partner should allocate to each partner who is an individual, a share of these two amounts. The individual partner can then claim tax credit relief or relief by deduction on the personal tax return. Similarly repayments of foreign tax (LLM7070) should be allocated by the nominated partner to every partner, who then have to report in personal tax returns according to how each of them had relief for the amount now refunded.
The nominated partner should show the nature of the income as 바카라 사이트˜Lloyd바카라 사이트™s SLP trading profits바카라 사이트™ in the 바카라 사이트˜Additional information바카라 사이트™ box of the Partnership Tax Return, and each partner바카라 사이트™s share of the partnership trading profits as 바카라 사이트˜Share of foreign profits바카라 사이트™ in the Partnership Trading Pages. Their 바카라 사이트˜Share of foreign tax paid or suffered바카라 사이트™ on this income is their share of the foreign tax pool.
Foreign tax arising on foreign source interest or dividends that is included in the partnership trading profits is not reported and allocated separately on the Partnership Foreign Pages.