• Part 10: Part 10: Limited Liability Partnerships

    • Article 63 - Policy Statement on LLPS

      An LLP is liable to tax under these Regulations as if it were a separate legal entity. There is a restriction on the deduction allowable for Members' Remuneration.

      Amended (as from 18th July 2019)

    • Article 64 - General Scheme for LLPS

      This Part contains provisions relating to:

      (a) Limited liability partnerships incorporated or established under the Limited Liability Partnership Regulations 2005; and
      (b) Non-QFC Limited Liability Partnerships that have registered under Part 10 of the Limited Liability Partnership Regulations 2005,

      each referred to as an LLP.

      Amended (as from 18th July 2019)

    • Article 65 - Computation of Chargeable Profits of LLPS

      (1) In arriving at the Chargeable Profits of an LLP for any Accounting Period, an LLP is entitled to a deduction in respect of any Remuneration paid to Members of the LLP that is considered just and reasonable by the Tax Department up to a maximum of 50% of the Chargeable Profits of the LLP for that Accounting Period, as calculated prior to the deduction of Members' Remuneration.
      (2) A Member of an LLP is:
      (a) in respect of a limited liability partnership established or registered under the Limited Liability Partnership Regulations 2005, as defined by Article 11 of the Limited Liability Partnership Regulations 2005; or
      (b) in respect of a Non-QFC Limited Liability Partnership, a person who is considered a member of the Non-QFC Limited Liability Partnership under the law of incorporation or establishment of the Non-QFC Limited Liability Partnership.
      (3) References to a “Member” in Article 65(1) shall also include Disguised Members.
      Amended (as from 18th July 2019)