UK International Trading Vehicle

What is Limited Liability Partnership (LLP)?

  • It is an incorporated entity giving the benefits of limited liability to its members (partners).
  • It is a separate legal entity requiring two or more members

Key Points

  • International business operated by non-UK resident members is not chargeable to UK taxation, provided members are non-UK resident and there is no UK-source income.
  • No minimum capital requirement.
  • Requirement to file annual return and accounts with Companies House.
  • Requirement to file partnership tax returns.
  • Tax transparent, therefore taxation is based on the residency of its members.
  • The members may have a tax liability in their own jurisdictions.
  • LLP statutory documents are on public record and available from Companies House.
  • Same day incorporation available.
  • Corporate members can be appointed (non-natural persons).

Who would the LLP benefit?

  • Businesses where there is no UK-source income.
  • Members and beneficial owners who are non-UK resident.
  • Opportunities are optimised when UK LLPs are formed to carry out non-UK business by clients in zero or low tax jurisdictions.
  • Suitable for members resident in multi-jurisdictional countries as tax liabilities are transparent and can be dealt with on a member-by-member basis in their home country.

Where and why set up the LLP

  • Serviced by single point of contact from any of our offices.
  • Cost effective pricing structure.
  • Speed and efficiency of set up.
  • Presence of an established UK office.
  • In-house ability to maintain the accounting records and statutory filing obligations.
  • Fiduciary Management Services (UK) LLP is regulated by The Charted Association of Certified Accountants.

Sample costings for a UK LLP:

  • Initial set up fee                                                                  £1,750

    Includes incorporation, LLP documents, undertaking due diligence and making an application to open a bank account.
  • Annual administration fees                                               £2,414

    Includes domiciliation, provision of Fiduciary members, preparation and filing of tax returns and financial statements.

    Addititional administration and accounting services over 10 hours costed into the above is charged on a time-spent basis. Charge out rates are between £60 and £150 per hour.

How this works in practice:

Mr Rock lives in Dubai, a no tax jurisdiction, and is tax resident there. He sets up a Dubai Company, buys cork from Portugal and sells them to department stores in EU member countries.

His suppliers and customers increasingly feel uncomfortable in trading with companies from low tax jurisdictions.

Mr Rock's advisers make him aware that he can use a UK LLP for trade without exposure to UK tax. He approaches a Gibraltar-based corporate service provider to discuss the benefits of setting up a UK LLP with local Gibraltar-based resident Fiduciary members.

As an alternative, if Mr Rock was not resident in a low or no tax jurisdiction he could relocate to Gibraltar under one of their preferential tax regimes and cap the total tax chargeable on worldwide income to a maximum of £29,880

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.