Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.
This is my third article on this case this time reacting to the judgment of the Court of Appeal in BCM Cayman LP and BlueCrest Capital Management Cayman Ltd v HMRC [2023] EWCA Civ 1179. That judgment and so this article only focuses on two aspects of BlueCrest’s overall arrangements which are now the subject of three separate strands of tax litigation. Those aspects which are of general interest to advisers on the UK taxation of partnerships are (a) who is the taxable person where the partner of record has transferred the benefit of its entitlement to partnership distributions; and (b) can a non-UK corporate partner in a UK trading partnership claim a deduction for its finance expense on...
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Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.
This is my third article on this case this time reacting to the judgment of the Court of Appeal in BCM Cayman LP and BlueCrest Capital Management Cayman Ltd v HMRC [2023] EWCA Civ 1179. That judgment and so this article only focuses on two aspects of BlueCrest’s overall arrangements which are now the subject of three separate strands of tax litigation. Those aspects which are of general interest to advisers on the UK taxation of partnerships are (a) who is the taxable person where the partner of record has transferred the benefit of its entitlement to partnership distributions; and (b) can a non-UK corporate partner in a UK trading partnership claim a deduction for its finance expense on...
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