In BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) (reported in Tax Journal 8 July 2022) the First-tier Tribunal (FTT) allowed the taxpayer’s appeal in part finding that the salaried members rules applied only to those members who did not have significant influence over the LLP’s business. Significant influence in this case was found to be financial and it was sufficient for that influence to be over one or more aspects of the LLP’s business rather than over the affairs of the LLP as a whole.
This is the first significant case on this relatively new legislation. As such it will doubtless be the subject of much debate by practitioners in this area.
Emily Clark and Ian Zeider of Travers Smith noted that the decision was on the whole favourable for taxpayers. ‘In...
