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04 Dec 06 Treatment of UK Limited Liability Partnerships under foreign hybrid rules

In a press release issued on 1 December 2006, the Minister for Revenue and Assistant Treasurer, Peter Dutton, announced that the Government will use its regulation making power to ensure that United Kingdom limited liability partnerships are treated as a partnership by the foreign hybrid laws.

The foreign hybrid laws were enacted in 2004 to address adverse taxation implications that can result from Australia treating a foreign hybrid entity as a company for tax purposes, while the foreign jurisdiction treats it as a ‘look-through’ entity such as a partnership. Mr Dutton said, “I have been advised that United Kingdom limited liability partnerships do not currently fall within the foreign hybrid rules. The Government does not consider this is an appropriate outcome.” The design of the regulation will be the subject of targeted consultations.

For a copy of the Minister's press release, No 2006/085, 1 December 2006, go here

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