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Ruling Signals Change in French Tax Treatment of LLP Distributions
Earlier this year, the French authorities signaled that a welcome change may be afoot in the tax treatment of distributions from UK LLPs under French law. (Most U.S. firms operate in France through the UK, unless they are grandfathered and in practice in France since the early 1990s.) This article discusses the scope of the ruling and its ramifications for UK firms considering a LLP conversion or those already in or contemplating alliances with French firms.
Background
Until very recently, there was no equivalent entity to a limited liability partnership under the French tax system, and this has created uncertainty about the appropriate tax treatment of partner distributions under French tax law. Under French law, the key issue is whether income flowing to a partner should be treated as flow-through income or whether it should be deemed a dividend and taxed at the entity level. In the UK and the United States, such distributions are considered flow-through income, which is reported by and taxable to the partner directly. This treatment avoids double taxation and is seen as a key benefit of the LLP structure.
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