(1)[deleted]

(2)

[deleted]

(3) In the Taxation of Chargeable Gains Act 1992 [1992 c. 12.], after section 59 insert-

"59A Limited liability partnerships

(1) Where a limited liability partnership carries on a trade or business with a view to profit-

(a) assets held by the limited liability partnership shall be treated for the purposes of tax in respect of chargeable gains as held by its members as partners, and

(b) any dealings by the limited liability partnership shall be treated for those purposes as dealings by its members in partnership (and not by the limited liability partnership as such),

and tax in respect of chargeable gains accruing to the members of the limited liability partnership on the disposal of any of its assets shall be assessed and charged on them separately.

(2) Where subsection (1) ceases to apply in relation to a limited liability partnership with the effect that tax is assessed and charged-

(a) on the limited liability partnership (as a company) in respect of chargeable gains accruing on the disposal of any of its assets, and

(b) on the members in respect of chargeable gains accruing on the disposal of any of their capital interests in the limited liability partnership,