Hogan Lovells has asked its non-equity partners to contribute up to £100,000 in capital to the firm in response to limited liability partnership (LLP) tax changes being brought by HM Revenue & Customs (HMRC).

Around 65 salaried partners at the firm will have to contribute between  £60,000-£100,000 each to meet the new requirements. The firm has said that loans will be available from banks on the same terms as those available to equity members.

HMRC published proposals for changes to the LLP tax regime in December.

It intends to close a loophole in existing legislation that allows partners with a low stake of the equity to be termed as self-employed, meaning that firms can avoid paying national  insurance contributions (NIC) for them.

According to HMRC's new rules, firms must put in place a binding commitment to increase capital before 6 April, with capital to be contributed within three months of the date.

A spokesperson for Hogan Lovells said: "We are having to act in anticipation of the final rules, which come into effect from 6 April.

"Our approach is to ensure that the terms for non-equity members are fair to both them and the firm and that our non-equity members are treated by HMRC as the partners that they are. The capital itself doesn't need to be paid until early July."

Several firms are reviewing their capital contribution structures in response to the upcoming changes, including Baker & McKenzie. Bakers is asking approximately 25 non-equity partners in its London office to contribute just over a quarter of expected annual earnings in order to exempt them from employee status.

Field Fisher Waterhouse is looking at a similar deal for any of its 50 or so UK-based fixed-share partners who could be caught out by the new rules, though financial director Mike Giles anticipated that "not many" partners will be affected by the changes. The firm does not have any salaried partners.