Chapter II of the Limited Liability Partnership Act, 2008: Nature of Limited Liability Partnership
Comparative Analysis with Other Jurisdictions
India’s LLP framework draws inspiration from but differs from LLP regimes in other countries:
| Jurisdiction | Separate Legal Entity | Designated Partners/Managers | Minimum Partners |
| India | Yes (Section 3) | At least 2 designated partners, one resident in India | Minimum 2 partners |
| United Kingdom | Yes, body corporate | Members, some may be designated | Minimum 2 members |
| United States | Varies by state; generally yes | Managing partners or all partners | Varies by state (typically 2) |
| Singapore | Yes, separate legal entity | At least 1 manager resident in Singapore | Minimum 2 partners |
| Australia | No, partners own property | Partners or designated partners | Minimum 2 partners |
Table 2: Comparative LLP frameworks
India’s model is most similar to Singapore’s, with emphasis on resident designated persons for compliance accountability[49].
