The result of the BlueCrest appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
The case of BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) is the first appeal against HMRC’s application of the salaried members rules which were introduced into ITTOIA 2005 ss 863A–863G in 2014. We represented the appellant taxpayer as counsel before the First-tier Tribunal (FTT). There are therefore necessarily some things this article cannot cover 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.
Where the salaried members legislation applies a partner in a limited liability partnership (LLP) is treated as an employee of that partnership for the purposes of income tax and NICs. BlueCrest is...
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The result of the BlueCrest appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
The case of BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) is the first appeal against HMRC’s application of the salaried members rules which were introduced into ITTOIA 2005 ss 863A–863G in 2014. We represented the appellant taxpayer as counsel before the First-tier Tribunal (FTT). There are therefore necessarily some things this article cannot cover 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.
Where the salaried members legislation applies a partner in a limited liability partnership (LLP) is treated as an employee of that partnership for the purposes of income tax and NICs. BlueCrest is...
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:
