While there have been a number of recent cases concerning the tax treatment of partnership incentivisation arrangements, the recent decision in The Boston Consulting Group UK LLP & others v HMRCmay be viewed as an extension of the principles derived from those cases (in particular, on the scope of the charge to ‘miscellaneous income’), in the context of arrangements intended to give partners a long-term, ‘equity’ interest in the business in which they operate. The case also provides much-needed further guidance on how future tribunals might apply the so-called ‘mixed member rules’ in ITTOIA 2005 s 850C.
If you are not a subscriber, subscribe now to read this content.
While there have been a number of recent cases concerning the tax treatment of partnership incentivisation arrangements, the recent decision in The Boston Consulting Group UK LLP & others v HMRCmay be viewed as an extension of the principles derived from those cases (in particular, on the scope of the charge to ‘miscellaneous income’), in the context of arrangements intended to give partners a long-term, ‘equity’ interest in the business in which they operate. The case also provides much-needed further guidance on how future tribunals might apply the so-called ‘mixed member rules’ in ITTOIA 2005 s 850C.
If you are not a subscriber, subscribe now to read this content.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
