Market leading insight for tax experts
View online issue

BCM Cayman LP and others v HMRC

In BCM Cayman LP and others v HMRC [2020] UKFTT 298 (TC) (17 July 2020) the FTT considered a number of complex appeals relating to the tax treatment of transactions involving a limited partnership and its partners.

BlueCrest Capital Management LP (BCM LP) was a limited partnership operating as an investment manager. By 2007 it had one general partner and 51 limited partners. Three of the limited partners wished to sell a proportion of their interest in the partnership amounting to 19% of the total equity. A complex structure was established in the Cayman Islands to enable the interests in the partnership to be purchased by an entity within BlueCrest. A Cayman Islands company (BCMCL) was established and in part using funds borrowed from a bank it purchased the interest in BCM LP. It then contributed its interest as capital to a Cayman Islands limited...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top