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LLP management and control issues


For the UK corporate tax, and income tax, the purposes LLPs are treated as partnerships, with the result that the offshore corporate members will be treated as carrying on the activities of the LLP in partnership. Assuming, that offshore (it can be companies registered in BVI, Belize, Seychelles, etc.) are centrally managed and controlled outside of the UK, and the LLP will be (in UK tax terms) a non-UK resident partnership.