There is a Limited Liability Partnership with only two members: a limited company and a foundation, each non-resident in the UK, with no UK-resident individuals involved. The limited company contributed 10% of the LLP's capital, the foundation - remaining 90%. The profit share set out by the partnership agreement is £10,000 annually for the limited company, any remaining profit for the foundation. There is also a provision that requires any profit over £10,000 to be retained by the LLP as a reserve. It is important to note that the tax rate for the company is 15% and for the foundation it is 0% in their respective jurisdictions.
Is HMRC likely to launch an investigation under these circumstances? As neither member is a UK resident, would they take time and effort to investigate the LLP?
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