Consider the following situation:
- A UK LLP is used to hold shares in a foreign private company
- Its sole purpose is to hold these shares for the Partners, it has no other trading or activities
- The partners obviously wish to realise capital gains tax and not income tax once the investment is sold
What are the considerations that the Partners would need to make in order to achieve CGT? E.g. Is there a risk HMRC would consider share trading to be a revenue stream and therefore taxed as income?
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