UK Limited Partnerships

Limited Partnerships registered under the UK Limited Partnerships Act 1907  are very popular in  international tax planning arrangements because the “partnership” itself is tax transparent and taxation is levied only at the level of the “partners” rather than the entity.  So for example if the partners or members are resident outside the UK, manage the LP from outside the UK and there is no income in the UK then there would be no taxation at all in the UK. 

Partners or members can be non-resident or offshore corporate entities.  For example two offshore companies can be partners or members of the UK LP.  The UK LP can be registered in the UK under English or Scottish law.  The names of the partners (offshore companies), the UK registered office address and the capital contribution (if any) will be disclosed at UK Companies House.  The LP can enter into contracts. 

LPs are used commonly in private equity and hedge fund arrangements.