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Influential, again: the BlueCrest salaried members appeal

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In HMRC v BlueCrest Capital Management (UK) LLP, the Upper Tribunal upheld the decision of the First-tier Tribunal in full in the first case on the salaried members rules relating to the treatment of partners in limited liability partnerships. This is the first binding judicial consideration of the term ‘significant influence’ in tax legislation. The UT agreed with the taxpayer on the construction of the term ‘significant influence’ and found that BlueCrest had successfully demonstrated to the FTT that the majority of the appellant’s portfolio manager partners were outside the salaried members rules. ‘Influence’ for these purposes need not be managerial or to extend to every aspect of the LLP’s business; it can take into account financial influence and be limited to a part of the LLP’s wider business.

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