The government will remove the presumption of self-employment for limited liability partnership (LLP) partners, to tackle the disguising of employment relationships through LLPs and counter the artificial allocation of profits to partners (in both LLPs and other partnerships) to achieve a tax advantage.

The misuse of the partnership rules has been a feature of many avoidance schemes closed down in recent years and the government announced on 5 December 2012 that HMRC would consider the taxation of partnerships.

As a result of this work, the government will consult on measures to remove the presumption of self-employment for limited liability partnership (LLP) partners and tackle the disguising of employment relationships through LLPs. It will also look at measures to counter the artificial allocation of profits to partners (in both LLPs and other partnerships) to achieve a tax advantage.

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