United Kingdom – LLP/Other jurisdictions

The United Kingdom (Great Britain) is one of the leading financial and business centres of the world, and is a significant jurisdiction for international tax planning. This country is known worldwide as a jurisdiction with a standard level of taxation, and therefore can in no way be thought of as a “tax haven”. Nevertheless, UK legislation provides the opportunity of incorporating and using bodies corporate with a zero rate of tax – namely, the LLP. 

The LLP – the limited liability partnership – is a body corporate having at least two members (partners), and is incorporated by completing the form LLP2 and a partnership deed and filing it at Companies House, the company registry for England and Wales. Accordingly, after completion of the registration process, Companies House issues a certificate of incorporation, and remaining company documents, such as general powers of attorney, warranties etc, come into being.
An English LLP with foreign members, which does not carry on a business in the UK and derives no income on UK territory, is not liable to tax in the UK. According to the tax laws of the Great Britain, company LLP is not considered in this country as the separate subject of the taxation, and from the profit received by company LLP its founders ("Members") in a place of the residence, in proportions according to shares of interests belonging them in LLP should pay taxes.

For example, the English company LLP having as founders one Panama Company and one company from BVI, and receiving the income only outside the Great Britain, will not be assessed in this country with the tax, and taxes will be paid by founders in the countries of the registration if it is stipulated by the legislation of the concrete country. Considering, that the tax on BVI and on Panama - 0 % at this scheme the general taxation of English company LLP makes 0 %.

In this way, an English LLP with the legally appropriate corporate structure and nominee members from tax-exempt jurisdictions is a vehicle with a zero rate of taxation.