The First-tier Tribunal judgments in Odey Asset Management LLP and HFFX LLP concern interesting points of law relating to remuneration arrangements in partnerships with mixed (individual and corporate) membership. Both FTTs found that funds allocated to the corporate member of an LLP as part of deferred remuneration arrangements were not subject to income tax in the hands of the individuals under ITTOIA 2005 s 850 in the year of allocation, but the amounts were subject to income tax when received by the individual members under the ‘miscellaneous income’ rules in ITTOIA 2005 s 687. The FTTs took different views on the application of the sales of occupation income provisions in ITA 2007 ss 773–778
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The First-tier Tribunal judgments in Odey Asset Management LLP and HFFX LLP concern interesting points of law relating to remuneration arrangements in partnerships with mixed (individual and corporate) membership. Both FTTs found that funds allocated to the corporate member of an LLP as part of deferred remuneration arrangements were not subject to income tax in the hands of the individuals under ITTOIA 2005 s 850 in the year of allocation, but the amounts were subject to income tax when received by the individual members under the ‘miscellaneous income’ rules in ITTOIA 2005 s 687. The FTTs took different views on the application of the sales of occupation income provisions in ITA 2007 ss 773–778
If you are not a subscriber, subscribe now to read this content.
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