Helen Coward, Guy Bud and Hugh Gunson (Charles Russell Speechlys) examine two decisions that raise interesting points of law relating to remuneration arrangements in partnerships with individual and corporate membership.
The taxation of fund managers has been under HMRC’s spotlight for some years now and there have been a number of targeted legislative changes between 2013 and 2016 (beginning with the salaried member and mixed membership rules and ending with the income based carried interest regime). That focus is now also evident in terms of litigation with a number of recent cases challenging historic planning.
Two recent cases – Odey Asset Management LLP v HMRC [2021] UKFTT 31 (TC) and HFFX LLP v HMRC [2021] UKFTT 36 (TC) – address interesting points of law relating to remuneration arrangements in partnerships with mixed (individual and corporate) membership. Both cases concern deferred remuneration arrangements established by limited liability partnerships...
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Helen Coward, Guy Bud and Hugh Gunson (Charles Russell Speechlys) examine two decisions that raise interesting points of law relating to remuneration arrangements in partnerships with individual and corporate membership.
The taxation of fund managers has been under HMRC’s spotlight for some years now and there have been a number of targeted legislative changes between 2013 and 2016 (beginning with the salaried member and mixed membership rules and ending with the income based carried interest regime). That focus is now also evident in terms of litigation with a number of recent cases challenging historic planning.
Two recent cases – Odey Asset Management LLP v HMRC [2021] UKFTT 31 (TC) and HFFX LLP v HMRC [2021] UKFTT 36 (TC) – address interesting points of law relating to remuneration arrangements in partnerships with mixed (individual and corporate) membership. Both cases concern deferred remuneration arrangements established by limited liability partnerships...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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