The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.
BlueCrest: salaried member rules
The Upper Tribunal (UT) has dismissed HMRC’s appeal and the taxpayer’s cross-appeal in the BlueCrest salaried members case (HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 232 (TC)). The decision will be of particular interest to LLP members in the investment management industry but is also relevant in any other business where individual LLP members have significant independent responsibility.
The salaried member rules are intended to ensure that individuals cannot escape employment income taxes where their working arrangement is effectively one of employment simply by becoming an LLP member instead of an employee. The rules treat an LLP member as an employee for tax purposes if all of three conditions (A B and C)...
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:
The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.
BlueCrest: salaried member rules
The Upper Tribunal (UT) has dismissed HMRC’s appeal and the taxpayer’s cross-appeal in the BlueCrest salaried members case (HMRC v BlueCrest Capital Management (UK) LLP [2023] UKUT 232 (TC)). The decision will be of particular interest to LLP members in the investment management industry but is also relevant in any other business where individual LLP members have significant independent responsibility.
The salaried member rules are intended to ensure that individuals cannot escape employment income taxes where their working arrangement is effectively one of employment simply by becoming an LLP member instead of an employee. The rules treat an LLP member as an employee for tax purposes if all of three conditions (A B and C)...
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:
f1dc7b1a-ffa1-4bc7-b492-3f4b8c14ee62.jpg?sfvrsn=b8086da2_1)
3342c09c-7948-4e1b-8023-7b2529f640a7.jpg?sfvrsn=64f059fb_1)
.tmb-editorspic.jpg?sfvrsn=c9a7a0cc_1)
