Inheritance Tax Act 1984 section 267A

Limited liability partnerships

Section 267A provides that for inheritance tax purposes, a limited liability partnership (LLP) is treated as a traditional partnership, so that its members are taxed as if they were partners in a partnership rather than members of a separate legal entity.

• Property owned, occupied or used by an LLP is treated as property belonging to, or used by, its individual members as partners.
• Any business carried on by an LLP is treated as carried on in partnership by its members.
• The incorporation, change in membership or dissolution of an LLP is treated as the formation, alteration or dissolution of a partnership.
• Any transfer of value made by or to an LLP is treated as made by or to its members in partnership, not by the LLP itself.