LLP with non-residents - HMRC investigation

[philly]

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?

[philly]

I forgot to mention - LLP has no UK-sourced income

[AnthonyR]

The LLP will still need to file accounts with Companies House and on registration HMRC would have been informed automatically (if registered in the last 3/4 years). As such HMRC will likely expect a tax return, even if there is no UK source income. In order to file the LLP return online you will need UTRs for both members, which will mean registering both entities for tax in the UK.

Is there a reason you are using a UK LLP for the offshore structure?