Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
In the recent BlueCrest cases the Upper Tribunal has confirmed on appeal all material aspects of the original decision. So the very short version of this article is: refer to my previous article on the decision at first instance. However before you stop reading please bear in mind that this decision (or in fact these decisions as the case has now been split into two) grapples with issues which go to the heart of the UK taxation of partnership income and reaches some surprising conclusions. In addition the Upper Tribunals remade some aspects of the decision and generally provided clearer reasoning for their findings.
BCM Cayman LP and Bluecrest Capital Management Cayman Ltd v HMRC [2022] UKUT 198 (TCC)
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Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
In the recent BlueCrest cases the Upper Tribunal has confirmed on appeal all material aspects of the original decision. So the very short version of this article is: refer to my previous article on the decision at first instance. However before you stop reading please bear in mind that this decision (or in fact these decisions as the case has now been split into two) grapples with issues which go to the heart of the UK taxation of partnership income and reaches some surprising conclusions. In addition the Upper Tribunals remade some aspects of the decision and generally provided clearer reasoning for their findings.
BCM Cayman LP and Bluecrest Capital Management Cayman Ltd v HMRC [2022] UKUT 198 (TCC)
For ease I set...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
