This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our Cookie Policy.
Analytics

Tools which collect anonymous data to enable us to see how visitors use our site and how it performs. We use this to improve our products, services and user experience.

Essential

Tools that enable essential services and functionality, including identity verification, service continuity and site security.

Where Taxpayers and Advisers Meet

Entrepreneurs' Relief - private equity limited partner

Brightonian
Posts: 99
Joined: Wed Aug 06, 2008 3:31 pm

Entrepreneurs' Relief - private equity limited partner

Postby Brightonian » Fri Aug 19, 2011 12:24 pm

I have been asked if Entrepreneurs' Relief is available to a limited partner in a private equity fund based offshore - he is UK resident and domiciled. From what I've been able to find out, a limited partner is just another name for an investor. He will receive a distribution of which 30% is return of capital and 70% is capital gain. The amounts are relatively small.
Does anyone know if it is possible for a limited partner in such an arrangement to obtain ER?

maths
Posts: 7553
Joined: Wed Aug 06, 2008 3:25 pm

Re: Entrepreneurs' Relief - private equity limited partner

Postby maths » Fri Aug 19, 2011 1:11 pm

Generally (but not always), offshore limited partnership structures are viewed as transparent by HMRC.

ER is unlikely as re any underlying investments (presumably shares) the investor will not be an employee thereof nor own 5%.

Brightonian
Posts: 99
Joined: Wed Aug 06, 2008 3:31 pm

Re: Entrepreneurs' Relief - private equity limited partner

Postby Brightonian » Fri Aug 19, 2011 2:04 pm

Thank you, Maths. I suspected that would be the case.


Return to “Capital Gains Tax, CGT”