BCM Cayman LP and others v HMRC

In BCM Cayman LP and others v HMRC [2020] UKFTT 298 (TC) (17 July 2020) the FTT considered a number of complex appeals relating to the tax treatment of transactions involving a limited partnership and its partners.

BlueCrest Capital Management LP (BCM LP) was a limited partnership operating as an investment manager. By 2007 it had one general partner and 51 limited partners. Three of the limited partners wished to sell a proportion of their interest in the partnership amounting to 19% of the total equity. A complex structure was established in the Cayman Islands to enable the interests in the partnership to be purchased by an entity within BlueCrest. A Cayman Islands company (BCMCL) was established and in part using funds borrowed from a bank it purchased the interest in BCM LP. It then contributed its interest as capital to...