• Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

  • Jul 15 2024
  • Length: 19 mins
  • Podcast

Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

  • Summary

  • In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.


    In this episode, we discuss:

    • Spotlight 63 and HMRC's view of property business arrangements involving hybrid partnerships and why HMRC consider such arrangements to be fiscally ineffective
    • the individuals and companies for whom Spotlight 63 might be relevant
    • what the consequences might be for those who have participated in the type of property business arrangements referred to in Spotlight 63.

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