The Chancellor announced in Budget 2013 that the government would consult on certain changes to aspects of partnership tax rules. HMRC has now published a consultation document focused on: Aspect 1: disguised employment – the disguising of employment relationships through Limited Liability Partnerships (“LLPs”); and Aspect 2: mixed partnerships and profit and loss allocations – the manipulation of profits and losses of partnerships and LLPs between partner/members to achieve a tax advantage. It is proposed that, following consultation, new legislation will be enacted with effect from 6 April 2014. It is important to note that whilst the legislation will not become effective until 6 April 2014, there will be no grandfathering provisions for existing arrangements and so the new rules will impact many existing partnership and LLP arrangements. Please click here to read the full article.