Market leading insight for tax experts
View online issue

BCM Cayman LP and another v HMRC

CA upholds FTT and UT decisions on limited partnership transactions.

In BCM Cayman LP and another v HMRC [2023] EWCA Civ 1179 (12 October 2023) the Court of Appeal (CA) dismissed the taxpayers’ appeals against the decisions of the Upper Tribunal (UT) and First-tier Tribunal (FTT) regarding (i) the tax treatment of tiered limited partnerships and (ii) the deductibility of loans incurred to invest in a partnership.  

Bluecrest Capital Management LP (BCM LP) was a limited partnership undertaking a trade of investment management. In 2007 a Cayman Islands company (BCMCL) took out a loan from a lender in order to acquire some of the limited partnership interests in BCM LP. BCMCL then contributed those partnership interests to a Cayman Islands limited partnership (Cayman LP).  As a result Cayman LP became a partner in BCM LP. BCMCL became the general partner of Cayman LP and the Lender became a corporate limited...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top