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BlueCrest and partnership taxation: presents under the tree

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The recent decision of the First-tier Tribunal in BlueCrest Capital Management Cayman Ltd covers some fundamental questions of UK tax including the treatment of tiered partnerships, the deductibility of loans to non-resident partners and the taxation of partnership distributions. The answers reached by the tribunal, if upheld, are likely to have implications for other taxpayers, particularly non-resident companies that are members of UK trading partnerships and individual partners that may have entered into remuneration planning arrangements. The decision is also notable for finding that a thinly capitalised SPV will not necessarily have its profits adjusted under transfer pricing rules.
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