Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.
Judgment has now been given by the Upper Tribunal (Edwin Johnson J and Judge Jennifer Dean) in HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 232 (TCC). The caseis the first appeal against HMRC’s application of the salaried members rules. We represented the appellant taxpayer as counsel as we had before the FTT. There are therefore necessarily some things this article cannot discuss because of the duties we owe to our client. We can however seek to draw out the important aspects of the judgment for the wider body of taxpayers and identify what lessons can be learnt.
Where the salaried members legislation applies a partner in a limited liability partnership (LLP) is treated as an employee of that partnership for...
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Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.
Judgment has now been given by the Upper Tribunal (Edwin Johnson J and Judge Jennifer Dean) in HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 232 (TCC). The caseis the first appeal against HMRC’s application of the salaried members rules. We represented the appellant taxpayer as counsel as we had before the FTT. There are therefore necessarily some things this article cannot discuss because of the duties we owe to our client. We can however seek to draw out the important aspects of the judgment for the wider body of taxpayers and identify what lessons can be learnt.
Where the salaried members legislation applies a partner in a limited liability partnership (LLP) is treated as an employee of that partnership for...
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:
