Court of Appeal remits salaried members case to FTT.
In HMRC v BlueCrest Capital Management (UK) LLP [2025] EWCA Civ 23 (17 January) the Court of Appeal (CA) considered an appeal by HMRC and the LLP’s cross-appeal against the Upper Tribunal’s (UT) decision on the application of the salaried members legislation in ITTOIA 2005 ss 863A–863G deciding that the question of whether certain members of the LLP satisfied Condition B in s 836C should be remitted to the FTT for rehearing. The CA upheld the decision of the UT that Condition A in s 863B was satisfied in relation to all of the relevant LLP members.
The LLP managed investment funds and also provided support services to other entities in its group. Portfolio managers ran the investment portfolios and were allocated an amount of capital over which they had discretion as to how to invest....
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Court of Appeal remits salaried members case to FTT.
In HMRC v BlueCrest Capital Management (UK) LLP [2025] EWCA Civ 23 (17 January) the Court of Appeal (CA) considered an appeal by HMRC and the LLP’s cross-appeal against the Upper Tribunal’s (UT) decision on the application of the salaried members legislation in ITTOIA 2005 ss 863A–863G deciding that the question of whether certain members of the LLP satisfied Condition B in s 836C should be remitted to the FTT for rehearing. The CA upheld the decision of the UT that Condition A in s 863B was satisfied in relation to all of the relevant LLP members.
The LLP managed investment funds and also provided support services to other entities in its group. Portfolio managers ran the investment portfolios and were allocated an amount of capital over which they had discretion as to how to invest....
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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